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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. ...
TCC

Jean-Louis Landry v. Her Majesty the Queen, [1995] 1 CTC 2030

The following is stated in Budget Papers of May 23, 1985, at page 56: A deduction from taxable income $2,590 in 1985- is allowed for a disabled person, currently defined as a person who is blind at any time in the year or confined to a bed or wheelchair for a substantial period of time each day. ...
TCC

Doris P. White v. Her Majesty the Queen, [1995] 1 CTC 2538, 95 DTC 877

And in Banff Park Savings & Credit Union Ltd. v. Rose et al. (1982), 139 D.L.R. (3d) 764, 22 Alta. ...
TCC

Wilmer Klein v. Her Majesty the Queen, [1995] 1 CTC 2980, 98 DTC 1950

It states that the appellant is indebted to Pioneer of four outstanding loans, namely: (a) $79,212 (b) $ 2,500 (c) $64,000 (This is the rights loan, Exhibit A-2) (d) the remainder of the $20,000 loan. ...
TCC

René Touchette v. Her Majesty the Queen (Informal Procedure), [1994] 1 CTC 2674

In so reassessing the appellant, the Minister made the following assumptions of fact: (a) the appellant is a Priest who, prior to 1991, was employed by the St-Jean Baptiste Parish (the "Parish") in St-Boniface, Manitoba; (b) the appellant was suspended by the Parish on September 15, 1990; (c) the appellant continued to receive his regular monthly salary in the amount of $1,392 until April 30, 1991; (d) commencing on May 1, 1991, the appellant was placed by the Parish/La Corporation Archiépiscopale C.R. de St-Boniface/La Société Ecclésiastique de St-Boniface (the "employer") on the employer's private pension and disability plan (the "plan"); (e) employees (priests) contribute five per cent of their monthly salary to the plan and parishes contribute two per cent of their Sunday collections; (f) no allocation between the pension plan and the disability plan is made with respect to employees’ contributions; (g) the plan paid the appellant 87 per cent of his regular monthly salary, namely 87 per cent of $1,392 = $1,211; (h) during the 1991 taxation year the appellant received disability (sick) benefits from May to December, i.e., 8 X $1,211 $9,688; (i) the employer charged the said disability benefits to its general ledger account #7202 "Maladie" (sickness); (j) the employer considered these disability benefits not to be taxable in the appellant's hands, and therefore made no deduction (of tax, etc.) and did not issue a T4 slip to the appellant in respect of these benefits; and (k) the appellant did not repay any portion of the said benefits received by him in the 1991 taxation year. ...
TCC

Araz Developments Inc., Sayouh Boyajian, Armine Boyajian, Ara Boyajian and Calabrina E. Boyajian v. Her Majesty the Queen, [1993] 2 CTC 2360, 93 DTC 922

The Minister by reassessment has included in computing each of the appellants' income for the 1988 taxation year an amount as follows: Proceeds $7,630,000 Cost of Sale (6,000,000) Selling Expenses ($124,000) Gain on Sale $1,505,206 Less: Reserve (109,602) Total Gain in Year $1,395,604 [Each] Appellant's Share (25 per cent) $ 348,900 Previously Included in Income as Taxable Capital Gain 232,600 Additional Income Assessed $116,300 In 1988, a 74.5 acre parcel of land adjacent to the subject property was acquired by Araz Developments (owned by Ara Boyajian) and Sebian Developments (owned by Sayouh Boyajian), in equal shares as tenants in common and this property is still held in the same ownership. ...
TCC

Rsi Research Ltd. v. Her Majesty the Queen (Informal Procedure), [1993] 2 CTC 2378

By letter (the “opinion letter") dated June 14, 1989 Thorne Ernst & Whinney delivered an opinion to the BCASI on the income tax implications of the BCASI making funds available to corporations such as the appellant for SRED purposes. ...
TCC

Maximo I. Rosales v. Her Majesty the Queen (Informal Procedure), [1993] 2 CTC 2852

Rosales’ 1986 taxation year, dated October 26, 1989, inadvertently contained an erroneous reference to Hutee Hydraulic Product" which has no relevance to the assessment of that taxation year. ...
TCC

Brian Ambler v. Her Majesty the Queen, [1993] 2 CTC 2996, 93 DTC 1460

It is not clear to me how the amount of $51,949 was determined because, as I read the judgment and the pleadings herein, the only payments made to Constance in 1985 were as follows: January, February and March @ $3,789.84 $11,369.52 Single Payment April 1, 1985 33,800.00 Total $45,169.52 The respondent has not disputed the quantum of the amount of $51,949 and so the only issue is whether the appellant is entitled to deduct in computing income for 1984 and 1985 the amounts of $45,478 and $51,949 respectively. ...
TCC

J. Allen Carr v. Minister of National Revenue, [1993] 2 CTC 3018, 94 DTC 1067

& Yukon Chamber of Mines report of January 31, 1971 indicated that ecological studies and water tests had already been conducted) and various news releases were indicating a much earlier date for contracted production (for example, Metal News, July 24, 1971, had reported plans for two million tons from "around 1973" and had outlined Japanese participation). ...

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