Search - 阿里拍卖 司法拍卖

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. ...

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. ...

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. ...

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? ...

According to the figures in Schedules I and II, the appellant’s income and profitability were as follows (all figures have been rounded off to the nearest thousand): Profit from Management Fees, Rentals & Gross Income Leases A Office Profit/Loss from Term Dqxwt from Farming 1987 21,000 30,000 31,000 1988 (95,000) 30,000 82,000 1989 (89,000) 27,000 121,000 1990 (98,000) 40,000 126,000 1991 (44,000) 14,000 103,000 During 1989, 1990 and 1991, the years in appeal, the farming activities of the appellant resulted in the following losses: $89,000, $98,000 and $44,000 respectively. ...

Counsel for the Appellant argued that there are special circumstances in this case, and in the other cases, which warranted the application — acceptance perhaps is a better word, of the due diligence of defence. ...

.: — These appeals were‘heard in Penticton, British Columbia on June 12, 1996. ...

. /?. [8] for the proposition that the word “goods” in section 125.1 “is used in the common parlance of merchandise or wares, or, to put it in legal jargon, tangible, movable... property”. ...

(hereinafter “Punters”) and the Appellant was responsible for administering Punters account; (c) The Appellant became involved with the principals of Punters, purchased shares in the corporation, assisted in issuing press releases, introduced potential investors to Punters and attended directors’ meetings; (d) The Appellant acquired and disposed of shares in Punters as detailed in schedule “A” attached hereto and his gains were in the following amounts: 1986: $129,573 1987: $46,731 1988: $ 17,125 (e) The shares acquired by the Appellant in January and March 1986 were acquired on the open market, the purchase price having been paid in cash; (f) The 100,000 shares acquired by the Appellant in June of 1986 were received from Robert Freeland for no cost as they represented a payment for services rendered (Robert Freeland was a venture capitalist and an important source of capital for Punters); (g) At all relevant times the Appellant’s intention was to profit from trading in Punters shares and at no time did he acquire or hold shares in Punters as an investment on account of capital. ...

.: — This appeal is from reassessments of the taxpayer for the 1991 and 1992 taxation years, notices of which were allegedly mailed to the Appellant on May 6, 1994, in which the Minister disallowed the deduction of rental losses, carrying charges and expenses. ...