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FCA

Wigmar Holdings Ltd. v. R., 97 DTC 5203, [1997] 2 CTC 263 (FCA)

(v) 173235 retained the unsecured debt (variously described as $1,281,110 or $1,150,000 the precise amount is not material) previously owed by 860 to Central Trust Company. ...
TCC

Dunlap v. The Queen, 98 DTC 2053, [1998] 4 CTC 2644 (TCC)

The Minister verified each of the said charges, per item, and the actual cost of the hotel room, as per invoices from the Ottawa Congress Centre and the Westin Hotel, and contained at Tabs 7 & 8 of the Respondent’s Book of Documents, and Schedule I and II herein. ...
FCA

Oerlikon Aérospatiale Inc. v. R., 99 DTC 5318, [1999] 4 CTC 358 (FCA)

Rolls Ct.) as cited by the Supreme Court in James Richardson & Sons Ltd. v. ...
QCCA decision

R. v. Les Habitations Perigord Inc., 88 DTC 6267, [1988] 2 CTC 64 (Que. C.A.)

.: La Couronne se pourvoit contre des jugements prononcés par la Cour supérieure, à Québec, les 11 novembre et 13 décembre 1985, par l'honorable juge en chef Pierre Côté (m.a. pp. 60 à 67). ...
FCTD

Dagenais v. The Queen, 95 DTC 5318, [1995] 2 CTC 100 (FCTD)

The plaintiffs received the following amounts as benefits under the plans: 1986 1987 1988 Dagenais $4,297.32 $10,166.28 $18,487.30 Halwachs N/A $13,852.72 N/A York N/A $ 2,092.80 N/A Paragraphs 6(1)(a) and 6(1)(f) of the Income Tax Act are the relevant statutory provisions in this appeal. ...
FCTD

Prior v. The Queen, 88 DTC 6207, [1988] 1 CTC 241 (FCTD), aff'd 89 DTC 5503 (FCA)

Valeo, supra, at p. 669 ”... every appropriation made by Congress uses public money in a manner to which some taxpayers object”. ...
FCTD

Greenbranch Investments Ltd. v. The Queen, 80 DTC 6384, [1980] CTC 514 (FCTD)

S & S Properties Limited v Her Majesty the Queen, [1978] CTC 412; 78 DTC 6294 at 419 [6298] where Walsh, J in quoting from Roy M Powers Her Majesty the Queen, [1975] CTC 580; 75 DTC 5388 and the judgment of Addy, J therein states: Yet, one cannot say that, as a matter of law, every land developer is precluded from establishing that in a particular case there was no primary or secondary intention to speculate anymore than in a case such as the one at Bar where a mature man has never previously resold a piece of real estate at a profit, is one precluded from finding that, on his very first venture in this sphere, he did in fact have the intention of reselling at a profit when he originally purchased the lands. ...
FCTD

Marotta v. The Queen, 86 DTC 6192, [1986] 1 CTC 393 (FCTD)

Michael’s carried with it an appointment to the University Dr. Marotta became a lecturer. ...
SCC

Sinnott News Company Ltd. v. The Minister of National Revenue, 56 DTC 1047, [1956] CTC 81, [1956] S.C.R. 433

It is in this sense he was understood by the learned trial Judge, who, on this footing, puts the issue as follows: “... the sole question to be determined is whether or not there was a sale of the goods by the company to the retailers.?? ...
SCC

Smerchanski v. Minister of National Revenue, 76 DTC 6247, [1976] CTC 488, [1977] 2 SCR 23

I set out the letter of commitment which was written to the special counsel retained by the tax department; it is as follows: Mr C Gordon Dilts, Barrister & Solicitor, 503 Electric Railway Chambers, WINNIPEG, Manitoba. ...

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