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TCC

Guerette v. R., [1996] 1 CTC 2780 (Informal Procedure)

.: Before commencing with the evidence counsel for the Appellant made a motion for the change of name of the Appellant from Guerette to Barnard as she had married since the filing of the Notice of Appeal. ...
TCC

Flexi-Coil Ltd. v. R., [1996] 1 CTC 2941

However, as it has often been said in tax cases- although usually where the taxpayer was trying to qualify for a tax benefit and not, as here, where the taxpayer is trying to avoid an adverse tax consequence that bookkeeping entries do not create reality. ...
FCTD

Mervin Holizki v. Her Majesty the Queen, [1995] 2 CTC 420

Robertson had an arrangement with a law firm in Regina, Thauberger & Company, that where a client did not have a lawyer and wished to incorporate, they would use one of the Thauberger "shelf companies" to try to keep the costs manageable. ...
BCCA decision

Her Majesty the Queen v. American Express Bank Ltd., [1995] 2 CTC 469

(See Sarna, Lazer, The Law of Declaratory Judgments, p. 1; Zamir &; Woolf, The Declaratory Judgment, second ed. 1993, p. 1.) ...
TCC

Reginald Watson and Deborah Madayag v. Her Majesty the Queen, [1995] 2 CTC 2460, 96 DTC 2006

Thill & Associates Inc. ("Thill") from Applied Research Ltd. ...
OntCtProvD decision

Her Majesty the Queen v. Antonio and Elsie Lusaya, [1994] 2 CTC 419

& P.E.I.R. 49, 301 A.P.R. 49, and I am advised by the Crown that that was dealt with on the basis that an auditor is not a person in authority, and therefore the rules as to confessions do not apply, and it would follow from that, that anything that was said to the auditor could be admitted without a voir dire, just as any sort of other admission in a legal proceeding could be admitted. ...
TCC

Healy Financial Corporation v. Her Majesty the Queen, [1994] 2 CTC 2168, 94 DTC 1705

It is agreed that all profits earned by NETWORK will be allocated as follows: (a) Zero to $120,000 to Healy Holdings (b) $120,001 and over 50 per cent to Healy Holdings and 50 per cent to Weber Holdings. ...
TCC

Gary Orzech, Executor of the Estate of Marcus Orzech v. Her Majesty the Queen, [1994] 2 CTC 2202, 94 DTC 1835

Conclusions (a) Highest & best use Because any use contemplated must be one that is reasonably feasible in an economic sense, it is imperative that appraisers focus on the market conditions as they existed at the relevant time. ...
TCC

Adrian L. Hamoen v. Her Majesty the Queen, [1994] 2 CTC 2278, 94 DTC 1915

On or about January 1, 1986, the appellant was the beneficial owner of an estate in fee simple in respect of various pieces of farmland which had been acquired before 1986 having the following legal descriptions: (i) NW 23-63-2-W5th ("Land No. 1 ") (ii) SW 23-63-2-W5th (“Land No. 2”) (iii) E 23-63-2-W5th (“Land No. 3”) (iv) NE 1-63-4-W5th ("Land No. 4") (v) NE 36-62-4-W5th ("Land No. 5") (vi) SE 6-63-3-W5th (“Land No. 6") In respect of his 1986 taxation year, the appellant had elected that his income from the farming business be computed in accordance with the cash method as defined in subsection 28(1) of the Income Tax Act, R.S.C. 1952, C. 148 (am. ...
TCC

Midland Transport Limited v. Her Majesty the Queen, [1994] 2 CTC 2303, 94 DTC 1759

(for Customs & Excise), [1984] C.T.C. 75, 84 D.T.C. 6081 (F.C.A.), the appellant used reusable bottle cases and carriers on the assembly line before and after soft drinks it manufactured were bottled. ...

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