Search - 阿里拍卖 司法拍卖

Gray has repaid all the loans and associated interest to me on the following basis: 1986 CAD 2,000.00 1987 CAD 15,000.00 + USD 10,000.00 1988 CAD 354,500.00 1989 CAD 157,500.00 1991 CAD 22,500.00 1992 CAD 468,750.00 6. ...

In so reassessing the appellant for the 1992 and 1993 taxation years, the Minister made the following assumptions of fact: (a) At all material times, the appellant was employed full-time as a commission salesman for Southey Farm Supply, which is located in Southey, Saskatchewan, approximately 200 kilometers from the farming property; (b) The time committed to the farming operation was minimized due to the full-time employment of the appellant as a sales representative; (c) In or about the month of February, 1991, the appellant purchased a residence in Regina in order to be located closer to his place of employment, which residence is significantly closer to his place of employment than the farm property at Saltcoats; (d) In 1991, the appellant sold a quarter section of farm property; (e) The appellant rented and occupied the Regina residence prior to his purchase of the said property; (f) The appellant earned the following amounts from his employment during the 1989 through 1990 taxation years respectively: Taxation Year Income 1989 $33,840 1990 38,687 1991 40,400 1992 58,009 1993 61,609 1994 64,838 1995 62,967 (g) Apart from the 1985 taxation year for which the appellant reported a profit in the amount of $5,179 during the taxation years 1979 through 1995, the appellant reported consistent annual losses from his farming operation; (h) With respect to that period, the appellant reported farming income (losses) as follows: Taxation Year Gross Income 1979 $73,238 1980 51,925 1981 75,455 1982 74,769 1983 95,935 1984 99,453 1985 55,219 1986 59,699 1987 51,141 1988 51,001 1989 59,292 1990 65,035 1991 90,583 1992 74,600 1993 40,998 1994 77,643 1995 36,771 Expenses Net Income (Loss) $80,373 ($ 7,135) 63,850 (11,925) 88,123 (12,668) Expenses Net Income (Loss) 89,421 (14,962) 109,051 (13,116) 102,640 (3,187) 50,040 (5,179) 64,335 (4,636) 51,686 (582) 62,153 (11,152) 84,307 (25,015) 98,175 (33,140) 125,747 (35,164) 115,643 (41,043) 99,252 (38,254) 113,713 (36,040) 82,369 (45,598) (1) Notwithstanding the significant losses over the previous 15 years, the appellant has no plans to alter the manner or type of farming operation from that of its present undertaking; (j) The appellant’s chief source of income during the taxation year was neither farming nor a combination of farming and some other source of income. ...

These minimal contributions enabled the curatorship to avoid paying administration fees. 9 On October 21, 1986, the curator was informed by the Service de la surveillance de l'administration des curateurs et tuteurs of the office of the Public Curator of Québec that [TRANSLATION] “a registered retirement savings plan is not a permissible investment consistent with those set out in arts. 981o et seq. of the Civil Code ”. ...

& D. Development Corp. and or suing same. Larry will not be an employee of the company, but will have a say in the day-to-day operations of the company. ...

However, with regard to determining the terms of the contract he said at 2057: I believe that where it is expressly or impliedly alleged in cases of the kind under appeal that a taxpayer having a relationship to a company similar to that which existed between the appellant and Coulter Copper & Brass Ltd. was acting as its agent in negotiating a verbal contract of employment with him, convincing confirmatory proof of some kind should be forthcoming to establish the terms of the contract relied on in making deductions in the computation of income. ...

If I set aside Route A which was an indirect acquisition of Omnibus shares by the Collyer Family Company (324) and not involved in this appeal, the Appellant's cost of his direct and indirect ownership of Omnibus shares and warrants may be summarized as follows: Omnibus Shares and Warrants Cost to Appellant Route B 4.4% of 0089 which held 8.06% of the Omnibus shares on May 11, 1987 $ 610 10,687 Route C 4.17% of 606 which then held 10% of the Omnibus shares 25,000 Route D 25,000 Omnibus shares plus 25,000 Omnibus warrants 100,000 Route E 3,333 Omnibus shares 15,000 Route F 24,870 Omnibus shares plus 9,257 warrants upon winding-up of 606 (25,000) 96,373 Totals 53,203 Omnibus shares plus 34,527 Omnibus warrants plus 4.4% of 0089 $222,670 It is the amount of $222,670 which the Appellant seeks to deduct in 1987 as a business loss. ...

.: — Ferme Klosterhos Inc. (Klosterhos) is contesting income tax assessments made by the Minister of National Revenue (the Minister) for the 1988, 1989, 1990 and 1991 taxation years. ...

If so determined, the second issue is whether the reassessment for the 1989 year is statute-barred or does the assessment fall within the provisions of subparagraph 152(4)(«)(i) of the Income Tax Act (the “Acf ’). ...

More precisely, having regard to the submissions of the parties, did each transaction give rise to an exempt supply as regards the Appellants. [57] Certain general provisions of the Goods and Services Tax portion of the Excise Tax Act should be kept in mind. [58] Section 165 enacts that every recipient of a taxable supply made in Canada shall pay to the Government of Canada tax in respect of the supply equal to 7 % of the value of the consideration for the supply, unless it is a zero-rated supply. [59] The definitions of certain terms and expressions of general import used in section 165 or elsewhere in the Excise Tax Act should be noted. ... "Alban Garon" J.T.C.C. [1]               Page 23b of the transcript, line 24 to page 24, line 12. [2]               Section 7 quoted above and referred to at the hearing of these appeals was amended by section 88, c. 10 of the Statutes of Canada, 1997 and was made retroactive to September 14, 1992 for certain purposes. ...

The usual rule — and I see no reason why it should not apply in income tax appeals — is set out in Odgers’ Principles of Pleading and Practice, 2nd edition at page 532: The “burden of proof” is the duty which lies on a party to establish his case. ...