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TCC

M.R.E. Developments v. The Queen, 2019 TCC 151

Brooks asserts he dropped into the local post box within or just outside his local drug store, Luke’s Drug Store in Calgary. ... And it need not be so dramatic; the Court must find in the circumstances, taken as a whole, that the uncorroborated evidence be credible, reasonable and sufficient. ... Brooks could not remember actually depositing the April Objection in the post box. ...
TCC

Anderson v. The Queen, docket 2001-3099(IT)I (Informal Procedure)

Auckland, admitted to an occasion of personal use of the vehicles. [5]            The pickup trucks have an extended cab with the rear seats removed so that the encased instruments which must be kept warm can be stored in a special tool box in the cab. ... The box of each pickup has a fitted tool box along each side and, usually, a tool box fitted behind the cab. ... Dramatic examples of what the Appellants do in the ordinary work day included Mr. ...
TCC

Arthurs v. The Queen, 2003 TCC 636 (Informal Procedure)

The Queen, 2003 TCC 636 (Informal Procedure)       Citation: 2003TCC636 Date: 20031113 Docket: 2003-57(IT)I BETWEEN: DOUGLAS HARRY ARTHURS, Appellant, and   HER MAJESTY THE QUEEN, Respondent.       ... In that particular case the taxpayer was, as described by the Chairman of the Tax Appeal Board, an "actress, commentator and dramatic artist. . . a star of the stage, radio and television and occasionally of the screen". ...   [16]     With respect to the expenses for such things as dry cleaning, eyeglasses, casual clothing, personal hygiene, a jewellery box, a picture frame, a season ski pass and other supplies, they are all of a personal nature and Mr. ...
TCC

Spearing v. The Queen, docket 2000-2106-IT-I (Informal Procedure)

Amway would sell a distributor an ordered product in a box of 12 regardless that the distributor's customer may have only placed an order with the distributor for one such product. ... The slide in revenues in 1994 and 1995 were somewhat due to circumstances according to the Appellant's testimony but the absence of further explanation for further dramatic revenue reductions suggest to me that the Appellant's efforts in regard to the business were winding down. ... The worst that can be said is that the business in the subject years evidences a dramatic slow-down in sales and that the trend in recent years evidences that the Appellant might be winding down his business and spending less time at it. ...
TCC

Restaurant Giovannina Pizzéria Inc. v. The Queen, 2016 TCC 244

This log was simple but reliable, particularly since a waiter had to initial every time a box was used for this purpose. ... (7,800/year, which corresponds to 40% of his annual pizza box purchases) My question is this: 1-       Over the years, have you ever come across a pizzeria that gave out so many doggy bags in a year?...” ... Each of the arbitrary and speculative assumptions used by the auditor was rejected on the basis of convincing arguments. [111]    In the light of the accountant’s testimony, it is reasonable to conclude that the exercises and scenarios put in place to quantify the number of boxes and their use generated results that were tangible and reliable as well as reasonable in terms of representing the reality that should be accepted. [112]    The testimonies of the accountant, Nicola Buffolino Jr. and Maria Buffolino, have revealed the following facts:                In the dining room, nine-inch boxes are mainly used for doggy bags; maintaining that it is necessary to apply the same percentage distribution to all box sizes is quite simply unreasonable;                A log was put in place to track boxes and box sizes over a two-month period and proves the accuracy of the Appellant’s assessment of the situation at the commencement of the audit;                The data garnered concerning the average number of pizza boxes used per transaction following installation of the new cash register system produced the following result: 2012 2013 2014 2015   July 31 July 31 July 31 July 31 Average 1.23 1.31 1.22 1.22 1.25                  According to the Respondent, one pizza box per transaction is given out to customers at the takeout counter based on an analysis of the cash register tapes. ...
TCC

Canadian Bar Insurance Assn. v. R, 99 DTC 653, [1999] 2 CTC 2833 (TCC)

Murray Bolger & Associates provided a number of services for the sponsored insurance program of the CBA. ... This joint account is the small box marked “A” at the top centre of Exhibit 5. ... On the evidence the earning of the interest income was not the purpose primary or secondary for which the fund was operated. ...
TCC

Cheek v. The Queen, docket 1999-1113(IT)G

The Appellant himself keeps a box score of each game so that he will know what has happened inning-by-inning. Exhibit A-8 is his box score of a game between the Blue Jays and the Cleveland Indians. [19]     Each party called an expert witness to support its respective position. ... The performing arts would also include dramatic acting whether on a live stage (theatre) or in the movies (motion picture). ...
TCC

Canadian Bar Insurance Assoc. v. The Queen, docket 96-2202-IT-G

The administrative services which the committee required had been contracted out to Murray Bolger & Associates which carried on business as a benefit plan administrator. [8] Murray Bolger & Associates provided a number of services for the sponsored insurance program of the CBA. ... This joint account is the small box marked "A" at the top centre of Exhibit 5. ... On the evidence the earning of the interest income was not the purpose primary or secondary for which the fund was operated. ...
TCC

800537 Ontario Inc. v. The Queen, 2004 TCC 258

Leon recorded an amount in the box labelled GST on subtotal (hereafter the "GST form"). ... In the Vendor's Acceptance Box on the USA EXPORT form: a)     Mr. ... The differences are fairly dramatic as is obvious from an examination of Appendix B to the ASF. ...
TCC

568864 B.C. Ltd. v. The Queen, 2014 TCC 373

Dennis Fitzpatrick, obtained the actual U.S. patent and on or about January 13, 2006 put it into his firm's safety deposit box and remained in the safety deposit box to date of this appeal. ... Young stated that the drop in construction of houses in the United States lead to a "dramatic" drop in the price of lumber. ... Patent Capitalized cost continuity schedule   Year end   Description   Amount   30-Sep-06   Defunct loan to Interact Wood Products   3,500,00.00   30-Sep-06     Legal costs to secure patent/intellectual property     300,596.92       Total capitalized cost at September 30, 2006     3,800,596.92     30-Sep-07   Legal costs to secure/defend patent   70,460.38       Subtotal   3,871,057.30 T2 sch 8 Class 14   30-Sep-07   Sold to Young Financial Ltd. for $1       Proceeds $1 and terminal loss     Total capitalized cost at September 30, 2007     (3,871,057.30)   30-Sep-08   additional costs paid to lawyer   24,159.00 (24,159.00)                        T2 sch 9 Class 14 addition and terminal loss [75]         Three years later, by agreement dated August 24, 2010 ("Legal Transfer Agreement"), PWC, as Trustee of the Estate of Mr.  ...

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