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T Rev B decision

Walter Dombroskie v. Minister of National Revenue, [1981] CTC 2407, 81 DTC 364

The Town was under some economic difficulties and there were no demands for additional lots hence, no land divisions for which municipal services would have had to be provided were being considered by the municipal board. ...
T Rev B decision

Gerald Reinders v. Minister of National Revenue, [1980] CTC 2798, 80 DTC 1687

He filed with the Board & set of headlines taken from the Richmond Review on dates between March 15, 1974, to December 12, 1975. ...
T Rev B decision

Rendell W Beck v. Minister of National Revenue, [1980] CTC 2851, 80 DTC 1747

I turn next to the more serious contention of the respondent, namely that the payment falls to be included in income by virtue of section 6 of the Act as a “... benefit of any kind... received or enjoyed... in the year in respect of, in the course of or by virtue of an office or employment.. it is plain that the payment in issue is one which resulted from the assertion by the Union, on behalf of the appellant and his fellow employees, of a claim for damages for breach of contract of employment. ...
T Rev B decision

Provisions St-Felix Limitée v. Minister of National Revenue, [1980] CTC 2875

In this assessment, the respondent included in the appellant’s income the sum of $217,113, a dividend apparently received from Pauzé & Chevrette Inc. 2.02 According to Yves Dufresne, counsel for the claimant, the original notice of assessment was never received by the appellant. ...
T Rev B decision

Royal Trust Corporation of Canada v. Minister of National Revenue, [1980] CTC 2900, 80 DTC 1780

The primary position of the appellant in these appeals was that in 1972 it paid amounts totalling $175,500 to an underwriter, Pitfield, Mackay, Ross & Company Limited (hereinafter called “PMR”) as a commission in respect of the sale of 325,000 shares of the capital stock of United and that in so doing it made an eligible capital expenditure. ...
T Rev B decision

Fioravante Pavan v. Minister of National Revenue, [1980] CTC 2956, 80 DTC 1830

For the respondent: From the notice of assessment Add: Your share of profit on sale of Part of lot, lots 33 & 7, Cone. 1, Township of Pickering $91,560.84 Unreported mortgage interest from sale of above property 6,874.30 98,435.14 Less: Paragraph 20(1)(N) mortgage reserve for 1973 64,753.15 33,681.99 From the reply to notice of appeal 4(a) In a transaction completed on 30 September 1969 the appellant, Gorizzan Holdings Limited (“Gorizzan”) and Romanin Bros Builders Limited (“Romanin”) acquired beneficial ownership in some 48 acres of lands in the Township of Pickering (“the Lands”) at a price of $238,595.80. ...
T Rev B decision

Denis Rousseau v. Minister of National Revenue, [1979] CTC 2056

L’évaluation de perte en capital pour l’entreprise de l’appelant fut établie d’après ce calcul à $106,000 tel qu’il appert à la Piece I-2 et la valeur des autres actifs de la transaction fut établie comme suit: Bâtisse $ 5,000 Equipement 10,000 Roulant 4,000 Total $19,000 Appreciation des Faits-■Le point du litige dans cette affaire n’est pas le montant de $19,000 payé pour la bâtisse, l’équipement et le roulant de l’appelant mais bien la nature du $106,000 reçu par l’appelant lors de la transaction. ...
T Rev B decision

David I Guttman v. Minister of National Revenue, [1979] CTC 2223, 79 DTC 243

From September of 1968 to September of 1973 the appellant carried on the practice of a chartered accountant with Edward John Court under the firm name Court, Guttman & Co. ...
T Rev B decision

DR Irvis Busch v. Minister of National Revenue, [1979] CTC 2275, 79 DTC 277

(See Cheshire & Fifoot’s Law of Contract, 8th ed, pp 202 and 203.) 2 That solicitor was not associated with the firm which acted for the appellant in connection with this appeal. ...
T Rev B decision

Canadian Pacific Hotels Limited v. Minister of National Revenue, [1979] CTC 2370, 79 DTC 274

Referring to the decision In re Bankruptcy of G & G Equipment Co Ltd, 74 DTC 6407, he said that the source of the funds determines the person who has the obligation to deduct and remit the money to the Minister. ...

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