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OntCtGD decision

Wildenburg Holdings Ltd. v. Ontario (Minister of Revenue)!, 98 DTC 6462, [1999] 2 CTC 161 (Ont. C.J. (G.D.)), aff'd 2001 DTC 5145 (Ont CA)

Both by statute (see the Partnership Act R.S.O. 1990 sec. 1) and at common law (see Lindley & Banks on Partnership, 17th Edition P.8) a partnership is the relation that subsists between persons carrying on a business in common with a view to profit. ...
OntCtGD decision

In Re Gaston H. Poulin Contractor Ltd., 92 DTC 6338, [1992] 2 CTC 373 (Ont. Ct. J. (Commercial List))

On or about November 6, 1991, Revenue delivered to the Federal Sales Tax Rebate (" FST Rebate”) section of its Customs and Excise branch (“Excise”) a notice issued pursuant to the Income Tax Act, section 224.1 requiring that the sum of $112,472.26 be retained by way of deduction or set-off from any amounts that may become payable to Poulin. ...
TCC

Bouchard Estate v. MNR, 93 DTC 1511, [1993] 2 CTC 3003 (TCC)

Napoléon Bouchard realized a capital gain of $153,810, hence a taxable capital gain of $76,905: Proceeds of disposition Fair market value at date of death (23/12/84) $228,000 Less: Median adjusted cost base: Cost Fair market value $57,100 Disposition $228,000 $57,100 Capital gain $170,900 Portion exempted as a result of a rollover (10 per cent) $17,090 Capital gain $153,810 Revised taxable capital gain (50 per cent) $76,905 [Translation.] ...
TCC

Red Deer Adviser Publications Ltd. v. MNR, 89 DTC 520, [1989] 2 CTC 2315 (TCC)

.: Red Deer Adviser Publications Ltd. appeals from a reassessment of income tax for its 1981 taxation year. ...
FCTD

Burgess v. The Queen, 91 DTC 5076, [1991] 1 CTC 163 (FCTD)

Whether the without prejudice” qualification in the letter of January 26, 1982 would vitiate the arrangement as an agreement is a question I have not addressed. ...
TCC

Kraft v. Minister of National Revenue, 99 DTC 693, [1999] 3 CTC 2185 (TCC)

. = whole body, company. 6. Used by Tindale to translate [illegible text] in the N.T., and much used by the Eng. ...
FCTD

McCaffrey v. The Queen and the Minister of National Revenue, 93 DTC 5009, [1993] 1 CTC 15 (FCTD)

Such arrangements as he did make for the receipt of mail during his absence from Canada between March 1988 and December 1989 broke down but that, surely, cannot be laid at the feet of the Minister who acted throughout in the manner required by the Act. ...
TCC

Young v. The Queen, 92 DTC 2387, [1993] 1 CTC 2015 (TCC)

Paragraph 4 also provides that Exhibit A-2 is "deemed to be terminated" and the Youngs discharge KFC from any claims and demands... arising out...” of Exhibit A-2. ...
TCC

Omstead v. MNR, 91 DTC 1244, [1991] 2 CTC 2615 (TCC)

.: By assessment, notice of which was mailed June 26, 1987, the respondent assessed the appellant to tax for the 1985 taxation year and levied interest of $10,790.88 pursuant to subsection 161(2) of the Income Tax Act, R.S.C. 1952, c. 148 (am. ...
TCC

Buckman v. MNR, 91 DTC 1249, [1991] 2 CTC 2608 (TCC)

(formerly Laventhol & Horwath Ltd.) (the "Trustee") was appointed as trustee in bankruptcy, which appointment was confirmed at a meeting of creditors on September 2, 1986. 3. ...

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