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Ken & Jesie Degrace Family Trust v. R, [1999] 1 CTC 2807 Bonner T. ...

A & a Jewellers Limited, [1977] CTC 428 The Associate Chief Justice:—This is an application under Rule 419(1)(d) for an order striking out the sentence: On or about the 21st day of July, 1976, the defendant was contacted by an official of Excise Tax Collections in Toronto who threatened to send a bailiff to the defendant’s premises or to take proceedings to attach accounts receivable if the amount demanded as aforesaid was not immediately paid. in paragraph 25 of the defence. ...

Deloitte, Haskins & Sells Ltd, Trustee of Pheonix v. Bank of Nova Scotia, 89 DTC 5355, [1989] 1 CTC 442 (Sask. ... Sherstobitoff, J.A.: — The issue in this appeal is whether a general assignment of book debts in favour of the respondent bank, duly registered under the Personal Property Security Act, R.S.S. 1978, c. ...

Collier & Son Ltd. v. The Deputy Minister of National Revenue for Customs and Excise, [1986] 2 CTC 375 Stone, J. ... Russell & Sons Ltd., [1973] 1 Q.B. 336 (C.A.). That case involved the time within which an action could be commenced for a fatal accident and it was held that the action had been commenced “within three years” laid down by the statute when it was commenced on the next day after that period had expired, the court office being closed on the last day of the period which was a Sunday. ...

Climac Hotels Ltd, B & C Hotels LTD v. Minister of National Revenue, [1985] 2 CTC 2312, 85 DTC 609 Brulé, TCJ [ORALLY]:—These two cases heard together, involved the purchases and sales of different hotel properties. As a result of these transactions the Minister reassessed Climac Hotels in its 1977 income tax year for the profit on the sale of a hotel as income rather than as a capital gain claimed, and in the case of B & C Hotels there were reassessments of its 1979 and 1980 income tax years on the same basis. ...

Canadian-American Loan & Investment Corporation Limited v. Minister of National Revenue, [1972] CTC 2559, 72 DTC 1463 A J Frost:—This is an income tax appeal in respect of the appellant’s taxation year ended June 30, 1967. ... By agreement dated September 30, 1966 the appellant entered into an agreement with Georgia which reads in part as follows: IN PURSUANCE OF THE “SHORT FORM OF LEASES ACT” Between: Canadian-American Loan & Investment Corporation Limited hereinafter called the “Lessor” of the First Part: And: Georgia Marina Boat Works Limited hereinafter called the “Lessee” of the Second Part: WITNESSETH, the said Lessor doth demise unto the said Lessee, his executors, administrators and assigns, ALL AND SINGULAR that certain parcel or tract of land and premises situate, lying and being in: the; Municipality of Richmond more specifically designated as Lot A of Lot 14 Block A Section 29 B.N. 5 R.W.6 Map 51813F and in particular the frame building thereon used for the purpose of housing boats of all kinds, under rental agreements with the owners, for various periods of time. ...

L & F Holdings Ltd. v. Minister of National Revenue, [1975] C.T.C. 2192, 75 D.T.C. 150 R St-Onge (orally: April 11, 1975): 1 This appeal is from a reassessment dated October 25, 1973 in respect of the 1972 taxation year and came before me on April 9, 1975 in the City of Winnipeg, Manitoba. ... She has also borrowed from her family the following amounts, which appear on the company's December 31, 1972 financial statement: (1) from her husband, Leon Raber $65,000 (2) from her daughter, Frayda Raber (20 years old) 6,100 (3) from her son, Lionel Raber (17 years old) 4,500 7 The appellant company's activity in 1972, 1973 and 1974 reveals the following transactions: (A) Money lent on mortgage: in 1972—Nil in 1973—one of $17,000 to Mr Bryck in 1974—3 mortgages (B) In 1972 the appellant company renewed four loans on promissory notes, namely: (1) Genevieve Holdings Ltd—$70,000 12.5% (2) Jean Horban (amount of loan not specified) 12.5% (3) Patricia Horban (amount of loan not specified) 10% (4) L Miles—$27,887.42 12% Besides the renewal of these four loans, the appellant company made three new loans on promissory notes. 8 In 1972 she was the only employee of the company and received $15,000 from her husband's business and nothing from her own company, but in 1973 she received $5,600 from the appellant company, which also paid $900 to each of her two children for answering the telephone and for making some deposits at the bank. 9 Mrs Raber's work for the appellant company was to contact clients, prepare the deposits, meet with the lawyer and accountant, collect the accounts receivable and keep the books of account. 10 As to the collection of money, all the payments were made by postdated cheques and the company had some 16 clients in 1972, most of them being friends of the family. 11 One of the clients, Sabray Investment Ltd, was owned by a Mr Hirsch and a Mr Gindin who were also clients of the appellant company. 12 Two weeks after receiving a letter from the Income Tax Department, addressed to the appellant company's accountant and saying that the company's income was not from an active business, a small advertisement was published in the Winnipeg Free Press saying: “Funds available for first and second mortgages—L & F Holdings Ltd—489–8560” 13 Mrs Raber terminated her testimony by saying that the appellant company did not have any trouble collecting its money; that in 1972 she had worked an average of four hours a day for her company; that in the same year she did not have any specific time to work for her husband although she was receiving $15,000 from him and nothing from her own company; and that out of an amount of $274,000 in loans, $200,000 was borrowed from members of her family. ...

James Richardson & Sons, Ltd. v. MNR, 82 DTC 6204, [1982] CTC 239 (FCA), rev'd supra. ... We now propose the following procedure in processing the information on a test basis: — we will supply magnetic tapes to be used by the corporation in copying the files for the 1977 calendar year. The corporation will provide us with record layouts and other technical information regarding the copied tapes. — the Department will guarantee the confidentiality of the data including assurances that no direct or indirect use will be made of any information obtained from the files during the test period. — on completion of the test period: (1) the Department will advise the corporation of any intent to use the information in an Income Tax compliance project and at that time, as discussed, we will serve a requirement for the information contained on these files. (2) the Department agrees to treat the other Canadian Commodity brokers in a similar manner by also requesting their files and using the information as required in the project. ...

Charges The corporations Salt &; Pepper Mexican Restaurant Ltd., and 370259 Alberta Ltd. ... As its sole Director, he was the only directing mind of Salt &; Pepper Mexican Restaurant Ltd. ... Silvio Solano is thus found guilty as charged on Informations # 40346496P1 and 40338618P1. ...

Johnson & Johnson Inc., 94 DTC 6125, [1994] 1 CTC 244 (FCA) Hugessen, J.A. ... A like result was reached in rather similar circumstances in Isaac Holden & Sons Ltd. v. ... Counsel for the Minister sought to rely on the Australian case of Sinclair & Sons Pty. ...