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TCC

Kahn-Tineta Horn v. Minister of National Revenue, [1989] 1 CTC 2208, 89 DTC 147

& W. 171; Rex v. Lovitt, (1912) A.C. 212] is that where a corporation has more than one residence and the payment of a simple contract debt owed by it has been localized either by the course of business between the parties or by the express terms of the contract, the situs of such debt is in the country where the payment of it has thus been localized. ...
TCC

Madeleine Dubé Charrier v. Minister of National Revenue, [1989] 1 CTC 2214

Applying this reasoning to the facts of the instant case, it would seem that the transfer of property to the appellant was a transfer made virtue of” the interim relief order within the meaning of subsection 160(4) of the Act, up to the amount of the arrears owed the appellant by Mr. ...
TCC

Gerd P. Weih v. Minister of National Revenue, [1988] 2 CTC 2013, 88 DTC 1379

., [1961] CR 85 at 98 where he said that these words "have the same meaning as ‘with all due diligence’ or ‘within a reasonable time' ”. ...
TCC

Granville K. Sheldon v. Minister of National Revenue, [1988] 2 CTC 2039, 88 DTC 1392

These provisions are incorporated as part of this Memorandum of Agreement as Appendix A Employee Assistance Agreement, attached to this document. ...
TCC

Christos Antoniou v. Minister of National Revenue, [1988] 2 CTC 2055, 88 DTC 1415

No order shall be made under subsection (1) (a) unless the application to extend the time for objecting or appealing is made within one year after the expiration of the time otherwise limited by this Act for objecting to or appealing from the assessment in respect of which the application is made; The present case must, at the outset, be distinguished from the line of cases where the notice of assessment was sent addressed to the taxpayer / elsewhere than at his actual mailing address. ...
ONDC decision

The Queen v. Compton Joseph Ferreira, [1988] 1 CTC 225

It is equally apparent to me that subsection 239(1) imposes a penalty but in these words, ”... and, in addition to any other penalty otherwise provided, is liable on summary conviction... ...
TCC

Estate of Lewis Ira Smith v. Minister of National Revenue, [1988] 1 CTC 2140, 88 DTC 1099

.: These appeals are in respect of the appellant's 1980, 1981 and 1982 taxation years and raised two issues. ...
TCC

Sara Shlien v. Minister of National Revenue, [1988] 1 CTC 2244, 88 DTC 1152

Taking this amount into account leaves a deficit in her net worth of $73,655.87 $22,300.00 $51,355.87. ...
TCC

John Thomas Ballard v. Minister of National Revenue, [1987] 1 CTC 2154, 87 DTC 157

He submitted that the letter "... is clearly a covenant which relates to what the employee is to do; he is to continue working for Canadian Fishing Company and on termination he will receive that amount.... ...
TCC

Donald B. Dodds v. Minister of National Revenue, [1987] 1 CTC 2265, 87 DTC 205

A schedule of gross income and expenses prepared and filed by the respondent shows: Net Profit Taxation Years Gross Income Gross Expenses (Loss) (Loss) 1978 $4,389.00 $ 7,983.29 ($3,594.29) 1979 2,494.64 2,554.96 (60.32) 1980 1,249.00 4,123.49 (2,874.49) 1981 205.00 6,011.27 (5,806.27) 1982 1,752.70 3,525.96 (1,773.26) 1983 937.60 6,638.68 (5,701.08) 1984 7,977.51 16,701.19 (8,723.68) The increase in expenses in 1984 over 1983 is accounted for mainly by an expense of $3,483.82 in respect of oil which was used as fuel for the production of maple syrup and additional capital cost allowance on what appears to be machinery and equipment purchased for the same purpose. ...

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