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FCA
Deputy Minister of National Revenue for Customs and Excise v. G.T.E. Sylvania Canada Limited, [1986] 1 CTC 131
There, a statutory tribunal had to construe the word “night” in a context which read: “... he is so severely disabled physically or mentally that he requires from another person, in connection with his bodily functions, frequent attention throughout the day and prolonged or repeated attention during the night...”. ...
TCC
Patrick W. Riddell, Sparkle Car Wash Ltd. v. Minister of National Revenue, [1986] 1 CTC 2500, 86 DTC 1374
There was no legal obligation upon Sparkle to make these payments in that they were the obligation of its sole shareholder — Riddell. ...
TCC
Fouad Mardini v. Minister of National Revenue, [1985] 2 CTC 2039, 85 DTC 434
Total income for the 1980 taxation year $144,011.00 Less: QPP contributions $ 212.00 Unemployment insurance premiums 204.00 RRSP 4,500.00 RHOSP 1,000.00 Financial costs $24,474.00 IAA 27,338.00* Other deductions 51,812.00 51,812.00 57,728.00 Net income 86,283.00 Personal exemptions 3,880.00 Charitable donations 150.00 Interest deduction 1,000.00 Capital loss carried back from 1981 43,511.00 48,541.00 Taxable income $37,742.00 *Point at issue Having regard to the deduction in respect of taxable dividends under s 121 of the Income Tax Act, the appellant stated moreover in the said amended return that he had no tax payable for the 1980 taxation year. ...
TCC
John Silburn v. Minister of National Revenue, [1985] 2 CTC 2071, 85 DTC 463
Mr Justice Mahoney of the Federal Court — Trial Division held that the defendant was resident in Canada throughout 1972. ...
TCC
R S Jackson Promotions Limited v. Minister of National Revenue, [1985] 1 CTC 2151, 85 DTC 145
In deciding this issue the Court considered other cases relied upon by the appellant, including The Queen v Ensite Limited, [1983] CTC 296; 83 DTC 5315; The Queen v Marsh & McLennan Limited, [1983] CTC 231; 83 DTC 5180, as well as the decision of the Federal Court of Appeal in Canadian Marconi Company v The Queen, [1984] CTC 319; 84 DTC 6267. ...
TCC
John F Heggie v. Minister of National Revenue, [1985] 1 CTC 2417, 85 DTC 357
On November 5, 1979, the appellant was employed as president and chief executive officer of Swift Canadian Co Limited (“Swift”) which was a wholly- owned subsidiary of Swift & Company of Chicago (“Swift US”) which, in turn, is owned by Esmark Inc. ...
FCTD
Albert Manley v. Her Majesty the Queen, [1984] CTC 8, 83 DTC 5440
In this case the damages were calculated by reference to two per cent of the purchase price of the Levy shares — what Manley would have been paid if the rest of the Levy group had been bound by the transaction between the plaintiff and Ben Levy. ...
FCA
Commonwealth Construction Company Limited v. Her Majesty the Queen, [1984] CTC 338, 84 DTC 6420
However, the next question to be asked is — is that situation affected by the fact that the amounts held to be payable by the judgments of Judge Ferg might have been varied if the appeals had been successful in whole or in part? ...
TCC
James D Rae, William R Jarvis v. Minister of National Revenue, [1984] CTC 2144, 84 DTC 1065
After purchase the farm operation continued under a 7,- */ crop sharing arrangement with the vendor Mr Clarence Hayes, with Mr Jarvis going out two or three times a year to look at the crop. ...
TCC
Nonico Investments LTD v. Minister of National Revenue, [1984] CTC 2696, 84 DTC 1624
What is the line which separates the two classes of cases may be difficult to define, and each case must be considered according to its facts; the question to be determined being — Is the sum of gain that has been made a mere enhancement of value by realising a security, or is it a gain made in an operation of business in carrying out a scheme for profit-making? ...