Search - 阿里法拍 司法拍卖

The financial results of 1966 to 1973, as submitted by the respondent, and not contradicted by counsel for the appellant, were as follows: Sa/es Sales Expenditures Losses in book business 1966 $4,872.24 $17,417.77 $12,545.53 1967 $2,308.92 $ 7,402.34 $ 5,093.42 1968 $4,150.10 $12,392.26 $ 8,242.16 1969 $8,428.46 $17,813.55 $ 9,385.09 1970 $3,427.24 $12,871.40 $ 9,444.16 1971 $6,723.02 $17,417.14 $10.694.12 1972 $2,822.90 $12,740.21 $ 9,918.31 1973 $ 734.16 $ 9,653.13 $ 8,918.97 3.8. ... The following is the appellant’s statement of income and expenditure for 1971, given as a typical example of the various expenditures which explained the appellant’s losses with regard to the publication and sale of his books: Net sale of books $ 6,723.82 Harpell Press: purchase of books $ 3,475.00 New York Times: advertising $ 6,260.50 Book World: advertising $ 1,415.63 Consumption [sic] of books $ 78.65 Printing of circulars $ 289.18 Clerical costs $ 3,000.00 A&C annuities and pensions, illness $ 99.72 Travel: book business $ 3,059.68 Bank charters $ 21.96 Nat photoengraving, text illustration S 419.71 C Podlone: text revision $ 360.00 Stationery $ 348.60 Bell Tel $ 31.38 Burnett, Appleby: purchase of names $ 225.40 Postage $ 943.53 $20,028.94 Increase in inventory $ 2,611.00 $17,417.94 Losses of book business $10,694.12 This statement of income for 1971 was admitted by the respondent as being representative of the other years concerned. 3.14. ...

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Ivesleigh Holdings Inc, Fontaine, Bilodeau & Cie Ltée, Baribeau & Fils Inc, Jeviam Inc v. Minister of National Revenue, [1978] CTC 2984 Roland St-Onge [TRANSLATION]:—The appeals of Ivesleigh Holdings Inc, Fontaine, Bilodeau & Cie Ltée, Baribeau & Fils Inc and Jevlam Inc were heard by me on September 16, 1977 in Quebec City, Quebec. ... For this purpose we Prepared the following tables for all the public companies which, according to our information, are operating in the broadcasting field: — price/earnings ratio for the principal radio and television broadcasting companies on December 31, 1971, including certain data on Télé-Capitale Limitée; — analysis by sector of operation of the principal radio and television broadcasting companies, including Télé-Capitale Ltée, in 1971; — percentage distribution of the gross revenue of the:companies, including Tele-Capitale Ltée, by sector of operation for 1970 and 1971. ...

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Roger Mercure■ ' I v. Minister of National Revenue, [1978] CTC 2215, 78 DTC 1165 Guy Tremblay [TRANSLATION]:—The case at bar was heard at Montreal, Quebec on June 9, 1977. 1. ... The following are the expenses which were disallowed, as they appear on the tax returns: 1971 1972 1972 1973 1973 Entertainment allowance $ 835.20 $1,235.20 $4,785.00 Business taxes $ 108.00 Automobile expenses $2,775.20 $6,900.00 Fire insurance $ 244.00 $ 485.00 Office expenses $ 265.00 Telephone $ 85.00 Travel expenses $1,325.00 $3,854.40 $8,620.20 $6,568.00 Less: 25% personal use $ 963.60 $2,155.05 $2,890.80 $6,465.15 $6,568.00 3./. ...

In those reassessments, the Minister levied the following federal penalties: Taxation Date of Year (Re)Assessment Penalties 1971 24 November 1977 $ 80.75 3 March 1978 $1,481.96 24 May 1979 $ 100.83 1972 24 November 1977 $ 631.23 3 March 1978 $ 822.83 24 May 1979 $ 643.85 1973 24 November 1977 $2,789.09 3 March 1978 $4,451.77 24 May 1979 $2,948.87 1974 24 November 1977 $2,570.56 3 March 1978 $3,460.75 24 May 1979 $2,681.11 1975 24 November 1977 $ 543.08 3 March 1978 $ 970.01 24 May 1979 $ 580.19 (k) The Appellant appropriated to his own benefit unreported revenue of MidNorth in the amounts of $2,807.41, $11,573.36, $18,402.72 and $900 respectively in his 1972, 1973, 1974 and 1975 taxation years. ... The same two persons (/ and plus Alan Hill (were partners in NIM Disposals. ... March 12 1973 5815 $ 1,229.30 BG; BL 2. March 26 1973 5861 2,000.00 BG; BL 3. ...

The appellant was not making investments and except for the two promissory notes (Exhibit A-2), nothing else — notes or preferred shares — had ever been issued by Link. ... The Minister has added the specific amounts noted earlier (1974 — $12,080.04; 1975 — $10,276.49; 1976 — $10,572.74; 1977 — $6,166.60) to the taxable income of the appellant rather than accepting the accounting treatment accorded “X” in the books of the company. ... The payments made as surcharges to purchase invoices were for the purpose of acquiring investments — a capital cost — and investments they remain at this stage of the process. ...

John Crosier, Lucille E Crosier, Albin Trella, Elizabeth Trella, Victor Prousky, Morris Prousky, 233482 Investments Limited, T Caravaggio & Son Limited, Manfred Feldt, Jean Mary Haschyc, Mendel Goldstein, Harry Teperman, David Irving Teperman, Burstein Bag Limited, Burstein Bag Limited v. ... The following schedule sets out the basic particulars of the property interest of the appellants: Property Year Appellants Appellants Karopa Hilltown 1974 John Crosier X 1974 Lucille E Crosier X 1974 Albin Trella X 1974 Elizabeth Trella X 1974 Victor Prousky X 1974 Morris Prousky X 1975 233482 Investments Limited X 1975 T Caravaggio & Son Limited X 1974 Manfred Feldt X 1974 Jean Mary Haschyc X 1974 Mendel Goldstein X 1974 Harry Teperman X 1974 David Irving Teperman X 1974 Burstein Bag Limited X 1975 Burstein Bag Limited X The following information directly relevant to the appellant Burstein is common to all appellants with respect to either one or the other parcel of real estate as indicated above: —The appellant held interest in two joint ventures known as Hilltown Developments Ltd (“Hilltown”) and Karopa Enterprises Ltd (“Karopa”); —The subject assets of these joint ventures were two pieces of raw land abutting each other in the Town of Oakville near the border line with the City of Mississauga; —The original participants and their respective percentage interests of Karopa were as follows: —Shortly after the purchase of the Karopa Property, Doug Roher and Lou Sherriff, the beneficial owners of K Roher Construction Limited and Lyrad Construction Limited respectively, which corporations in partnership owned Briar Developments, declared personal bankruptcy and thereafter Briar Developments ceased its participation in Karopa; Briar Developments (Roher & Sherriff) 29.7% Burstein Bag Limited 26.9% Crosier 1.4% Goldstein 1.7% McGuigan & Feldt 5.2% Prousky (Victor & Morris) 2.3% Trella (Elizabeth & Albin) 5.9% Warwick 11.2% Welta Wool.2% Feldstein 5% Flishlek.3% Rotsteins.3% Steiglan 6.6% Tomco 1.0% 233482 Investments Limited 7.7% 100.0% UUIJ I, IvVV, (“Karopa”) for $832,742.00 satisfied as follows: Cash $245,207.97 29.4% 1st Mortgage 301,867.03 36.2% 2nd Mortgage 50,750.00 6.1 % 3rd Mortgage 234,492.00 28.2% Taxes, etc 425.00.1 % $832,742.00 100.0% — During 1972, other participants of Karopa also encountered financial difficulties, and a reorganization occurred with the remaining participants taking over the vacated syndicate participation, the result being that the eventual composition of the Karopa joint venture was as follows: Burstein Bag Limited 35.720% T Caravaggio & Son Ltd 17.860% 233482 Investments Ltd 10.716% Jean Haschyc 5.706% Elizabeth Trella 5.706% Albin Trella 3.224% Joseph Rajca Jr 3.224% Mendel Goldstein 3.572% Manfred Feldt 3.572% Prousky (Victor & Morris) 3.556% John Crosier (husband & 1.786% Lucille Crosier wife) 1.786% Dorothy McGuigan 1.786% Beverly Young 1.786% 100.000 % Limited for a consideration of $1,901,664, realizing a gross profit of $1,068,922. ... No commission was paid by the group on the sale of the property. — In light of the whole history of the property, the amount received by the appellant as proceeds of disposition of its interest in that property was a Capital receipt. — In any event, the gain attributable to the portion of the appellant’s interest in the property that was acquired when Briar withdrew from the group was a Capital gain in that the appellant was forced to acquire that interest in order to protect its investment in the property. ...

The said application reads as follows: IN RE the Application under Section 174 of the Income Tax Act Between: CAVERHILL, LEARMONT & CO LIMITED, Appellant, — and — THE MINISTER OF NATIONAL REVENUE, Respondent, — and — CANADIAN HORTICULTURAL INDUSTRIES, Third Party. ... B) THE TAXPAYERS THAT THE RESPONDENT SEEKS TO HAVE BOUND BY THE DETERMINATION OF THE QUESTION ARE: — CAVERHILL, LEARMONT & CO LIMITED — CANADIAN HORTICULTURAL INDUSTRIES C) STATEMENT OF FACTS AND REASONS: 1. ... Horticultural Industries having participated in a common transaction with Caverhill, Learmont & Co Limited, an appellant before this Board, the Board orders that Canadian Horticultural Industries be joined to the appeal of Caverhill, Learmont & Co Limited. ...

The said application reads as follows: IN RE the Application under Section 174 of the Income Tax Act Between: CAVERHILL, LEARMONT & CO LIMITED, Appellant, — and — THE MINISTER OF NATIONAL REVENUE, Respondent, — and — CANADIAN HORTICULTURAL INDUSTRIES, Third Party. ... B) THE TAXPAYERS THAT THE RESPONDENT SEEKS TO HAVE BOUND BY THE DETERMINATION OF THE QUESTION ARE: — CAVERHILL, LEARMONT & CO LIMITED — CANADIAN HORTICULTURAL INDUSTRIES C) STATEMENT OF FACTS AND REASONS: 1. ... Horticultural Industries having participated in a common transaction with Caverhill, Learmont & Co Limited, an appellant before this Board, the Board orders that Canadian Horticultural Industries be joined to the appeal of Caverhill, Learmont & Co Limited. ...