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EC decision

The Royal Trust Company, Executor or the Estate of Amy Katherine McDonald, Deceased v. Minister of National Revenue, [1959] CTC 385, 59 DTC 1235

. $ 4,200.00 Automobile, Buick, bought in 1939 2,025.00 Property 520- 1st Avenue W. 4,800.00 Stocks and Bonds: 10 shares Canadian Utilities $ 1,000.00 15 ‘* Northwest Utilities 1,500.00 140 ‘* Calgary Power Co. 14,840.00 500 ‘** Chesterville 1,000.00 Dominion of Canada Bonds 12,000.00 $0,340.00. ... Taven- der said: They could have come from anywhere. As I recall his evidence, Mr. ...
EC decision

Muriel S. Richardson v. Minister of National Revenue, [1940-41] CTC 258

It held a large number of shares of the capital stock of James Richardson & Sons Ld., a grain company in which Mr. ... Richardson’s principal business was the grain company of James Richardson & Sons Ld. He had transferred to Interprovincial the stock which he owned in James Richardson & Sons Ld. and he had suggested to his relatives that they also transfer to Interprovincial their holdings in James Richardson & Sons Ld. ...
EC decision

Harry Dubrovsky and Louis Dubrovsky v. Minister of National Revenue, [1970] CTC 403, 70 DTC 6278

& D. Holdings Inc. the said land having an area of 4,500,966 square feet. 5. ... & D. Holdings Inc. were owned by Caracas Investment Corporation. 10. ... & D. Holdings Inc. and Advance Holdings Ine. On March 7, 1949 D. & D. ...
EC decision

Joseph Harold Wilson v. Minister of National Revenue, [1953] CTC 462, 53 DTC 1242

& J. Wilson” was owned and operated by J. E. Wilson, father of the appellant. ... & J. Wilson” direct to the widow. In the books of that business they were posted to ‘‘ Account of Mrs. ... & J. Wilson’’ might in that case lose possession thereof. Now “W. ...
EC decision

The Royal Trust Company, William Forrest Angus Chipman and J. R. Fraser, Executors of Walter William Chipman, Deceased v. Minister of National Revenue, [1952] CTC 68, 52 DTC 1107

(g) upon her husband’s death to dispose of the estate ‘‘as it may then exist as follows: 1. ... Where a general power to appoint any property either by instrument inter vivos, or by will, or both, is given to any person, the duty levied in respect of the succession thereto shall be payable in the same manner and at the same time as if the property itself had been given, devised or bequeathed, to the person to whom such power is given. Section 31 is complemented by Section 4(1) which reads as follows: ‘A person shall be deemed competent to dispose of property if he has such an estate or interest therein or such general power as would, if he were sui juris, enable him to dispose of the property and the expression “general power’’ includes every power or authority enabling the donee or other holder thereof to appoint or dispose of property as he thinks fit, whether exercisable by instrument inter vivos or by will, or both, but exclusive of any power exercisable in a fiduciary capacity under a disposition not made by himself, or exercisable as mortgagee.” ...
EC decision

Alexander B. Davidson v. Minister of National Revenue, [1963] CTC 240, 63 DTC 1154

Davidson & Co. Ltd. a corporation which has since then been engaged in underwriting and trading as a principal in securities. ... Denton who was a member of Burns Brothers & Denton Ltd., a company engaged in a business similar to that of A. ... Davidson & Co. Ltd., arranged to acquire some 54,000 shares representing 76% of the issued share capital of the company. ...
EC decision

The Royal Trust Company and Emma Louise Stevens, Executors of the Estate of Russell E. Smart v. Minister of National Revenue, [1948] CTC 21

He was also a partner in the legal firm of Smart & Biggar, of Ottawa. ... " " The Assignor, as of October 1st, 1928, with the consent of the Assignee and the Party of the Third Part, assumes all the assets and liabilities of the New York Office of Fetherstonhaugh & Co., and after such date the profits and assets of the New York Office shall belong solely to him. ... The only exception to the practice described in paragraph 18 arose from an advance made by Smart to Fetherstonhaugh, on the conclusion of the settlement, of $ on account of Fetherstonhaugh’s share of future profits; Smart paid this by a cheque on the account of Smart & Biggar; he recouped himself, and repaid Smart & Biggar, at first by depositing in Smart & Biggar’s account the whole of any profits from the Ottawa office of Fetherstonhaugh & Co., and paying no part to F. ...
EC decision

Interprovincial Pipe Line Company v. Minister of National E, :, [1967] CTC 180, 67 DTC 5125

., are deducted from ‘‘income for the year” to obtain his “taxable income’’ for the year (Section 2(3)); and where he is a non-resident person, to obtain his taxable income earned in Canada for the year, the reasonably applicable part of personal exemptions, business losses, etc., are deducted from the part of his ‘‘income for the year” that may reasonably be attributed to what he did in Canada (Section 31).] ... It is only ‘‘the appropriate amount of such taxes paid to the United States of America” that is has agreed to allow as a deduction ‘‘ As far as may be in accordance with... ... Having regard to the terms of the stated case, which contains an agreement as to the judgment that is to be delivered depending on the conclusion reached by the Court, the appeals are dismissed with costs. 1 * Compare Interprovincial Pipe Line Co. v. ...
EC decision

In the Matter of the Dominion Succession Duty Act and Amendments Thereto and in the Matter of the Administrators, Estate of Duke Osolin E Topor, [1968] CTC 434, 68 DTC 5263

Godin, Godin, Mehnert & Prud’homme, 1155 Dorchester Blvd., West, Room 808, Montreal, P.Q.’’. ... Godin, Godin, Mehnert & Prud’homme and directing the Sheriff to recover from them. ... The assessment was addressed to ‘‘ Administrators’’ without naming them. ...
EC decision

His Majesty the King v. Watt and Scott (Toronto) Ltd., [1945] CTC 259

In the case of the defendant Tees & Persse Limited, the excess values found on the fresh appraisals amounted to $131,947 and the amount of additional duty and taxes directed to be paid on the amended entries came to $63,955.18. ... The amount of additional customs duty and taxes found payable by the defendants as the result of these determinations was, in the case of the defendant Watt & Scott (Toronto) Ltd., the sum of $158,215.18 and, in the case of the defendant Tees & Persse Limited, the sum of $68,825.30. ... There will, therefore, be judgment for the plaintiff against the defendant Watt & Scott (Toronto) Ltd. for $158,215.18 and costs; and judgment for the plaintiff against. the defendant Tees & Persse Limited for $68,825.30 and costs. ...

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