Search - 辐射监测仪 校准
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TCC
Émile Mercier v. Minister of National Revenue, [1992] 2 CTC 2065, [1992] 2 CTC 2669
In reply to the appellants notice of appeal, the respondent ceased to rely on subsection 14(1) of the Act, and stated the opinion that the project received by the appellant [The French text reads: “le projet tire par l'appelant' — Translator] from the “sale” of his territory was deemed to be remuneration for services rendered by the appellant in the course of his employment, in accordance with subsections 5(1) and 6(3) of the Act. [1] At the beginning of the trial counsel for the respondent explained to the Court that notwithstanding the fact that her client relied on subsection 6(3) of the Act and that the entire amount of $15,000 should be added to Mr. ...
TCC
Seymour Pepper, Elaine Pepper, Dean Pepper, Brenda C. Pepper, Jody H. Pepper and York Super Pharmacy Limited v. Minister of National Revenue, [1992] 2 CTC 2259
The argument that somehow York loaned to York Boutique may be a fiction but at the same time the losses and the obligations encountered by York Boutique (the dollar basis of the alleged ” loan") were recognized as the responsibility of York—nothing could be clearer than that York eventually made good, in the name of York Boutique, for these amounts, totalling $69,000. ...
TCC
Kenneth Innes v. Minister of National Revenue, [1992] 2 CTC 2313, 92 DTC 1755
Queen & 5th, McBride July/85 $32,500 $28,200 2. 2nd Ave. Valemount Nov./85 $38,900 $32,700 3. 2nd Ave. ...
TCC
Brenda McNab v. Her Majesty the Queen (Informal Procedure), [1992] 2 CTC 2547
The appellant called as witnesses Isobel McNab, President of the Saskatchewan Treaty Indian Women's Council (hereinafter called the “ council”); Edith Dreaver, Executive Director of the council; Elizabeth Pratt, a secretary at the council and herself. ...
TCC
Jean Lemelin Inc. v. Minister of National Revenue, [1992] 2 CTC 2832, [1992] 1 CTC 2303, [1992] 1 CTC 2488, [1992] DTC 1584
First, the introductory part of subsection 224(1.2) clearly indicates that Parliament intended to confer on the Minister of National Revenue the right to compel a person who owed money to a tax debtor or to a secured creditor to pay the money to the Receiver General of Canada, ” notwithstanding any other provision of this Act, the Bankruptcy Act, any other enactment of Canada, any enactment of a province or any law”. ...
FCTD
James M. Shaw v. Her Majesty the Queen, [1992] 1 CTC 204, 92 DTC 6145
Further, it was easier in the Sani Sport case to connect the loss of business opportunity with the property because, as Marceau, J.A. pointed out, this amount represented the “ particular economic value that the land had for the expropriated party". ...
TCC
Frank Moauro v. Minister of National Revenue, [1992] 1 CTC 2129, 92 DTC 1071
His current financial records in relation to the horse operation with the use of the cash method and cost inclusion of new inventory in the year of purchase as expended show a clear direction towards profit: Summary of Horse Racing Activity and Horse Purchases, 1985 to 1990 Gross Revenue Total Expenses Net Loss Purchases' 1985 $26,321 $67,276 $40,955 $30,992 1986 38,458 60,735 22,277 18,340 1987 35,141 54,005 18,864 18,564 1988 27,582 32,681 5,099 — 1989 53,978 56,478 2,500 16,856 1990 66,967 69,944 2,977 12,000 NOTE: ...
TCC
Rideau Arcades Ltd. v. Minister of National Revenue, [1992] 1 CTC 2239, [1992] 1 CTC 2717
On this point, I accept the evidence of Jeffrey Schrier of the accounting firm of Friedman & Friedman, whose services had been retained by the appellant in 1983. ...
OntCtProvD decision
Her Majesty the Queen v. Franklin Cappell, [1991] 2 CTC 136, 91 DTC 5488
But, that language clearly suggests to this Court that both the lawyer and the Revenue officer are present because it says ”... the officer shall not inspect or examine the document and the lawyer shall... ...
ABPC decision
Her Majesty the Queen v. Ulla Mackenzie, [1991] 2 CTC 142
.: — Charge on or about January 18, 1990, at or near the City of Calgary, in the Province of Alberta, did unlawfully fail to file a completed and signed Individual Income Tax Return on Form T1 including a Statement of all Assets and Liabilities and a Statement of all Income and Expenses for the Taxation Year 1987 on or before January 17, 1990, as required in a Notice served November 17, 1989, pursuant to Paragraph 231.2(1)(a) of the Income Tax Act, contrary to subsection 238(1) of the Income Tax Act. ...