Search - 2002年 抽纸品牌 质量排名

  [61]          As a result the following amounts are allowed as expenses for maintenance and repairs in computing the Appellant’s income for 2001 and 2002:     2001 2002 Maintenance and Repairs $2,852 $600   Le Caine Enterprises – Office Expenses   [62]          The amounts claimed for office expenses for 2001 and 2002 were small. ... The following table lists the amounts as shown on the statements that were submitted and the amounts that will be allowed as a deduction in computing the Appellant’s income for 2001 and 2002:   Bill Date Amount on the Statement Amount Allowed for 2001 Amount Allowed for 2002 May 6, 2001 $51.12 $10.22   June 6, 2001 $48.34 $48.34   July 6, 2001 $49.22 $49.22   August 6, 2001 $39.48 $39.48   September 6, 2001 $41.18 $41.18   October 6, 2001 $51.14 $51.14   November 6, 2001 $46.08 $46.08   December 6, 2001 $36.46 $36.46   January 6, 2002 $39.36 $31.74 $7.62 February 6, 2002 $36.51   $36.51 March 6, 2002 $44.37   $44.37 April 6, 2002     $36.51 May 6, 2002     $29.21 Total:   $353.86 $154.22   [74]          The invoices for April 6, 2002 and May 6, 2002 were not included but there was an invoice for August 6, 2002 which indicates that the telephone was still connected. ...   [97]          For 2002, as noted above, it appears that the Appellant ceased to carry on business as of the end of April 2002. ...

[Emphasis added.] [40]         The Nouveau Petit Robert [37]   considers “ par suite de ” to be synonymous with “ à cause de ” or “ en conséquence de ”. ... Canada, 2012 FCA 258. [3]    2007 TCC 481, affirmed in 2009 FCA 163, affirmed in 2011 SCC 63. [4]   Written Submissions of the Appellants at para. 2. [5]   Ibid. at para. 14. [6]   Ibid. at para. 3. [7] Supra note 3 (FCA) at para. 3. [8]   2002 DTC 1254. [9]   Ibid. at para. 35. [10]             S.T.B. ... The Queen, 2002 FCA 386. [11]             Ibid.; leave to appeal to the SCC refused, 29517 (March 27, 2003). [12]             Michael Zander, The Law-Making Process, 4th ed. ...

The Queen, 96 DTC 6142, [1996] 2 CTC 14 (FCTD), rev'd 2002 SCC 47 Pinard J.T.C.C.: — These appeals are brought pursuant to subsection 172(2) of the Income Tax Act (the “Act”). ... The relevant provisions of the Act read as follows: 9. (1) Income.- Subject to this Part, a taxpayer’s income for a taxation year from a business or property is the taxpayer’s profit from that business or property for the year. 18. (1) General limitations.- In computing the income of a taxpayer from a business or property no deduction shall be made in respect of (a) general limitation.- an outlay or expense except to the extent that it was made or incurred by the taxpayer for the purpose of gaining or producing income from the business or property; 20(1) Deductions permitted in computing income from business or property. — Notwithstanding paragraphs 18(l)(a), (b) and (h), in computing a taxpayer’s income for a taxation year from a business or property, there may be deducted such of the following amounts as are wholly applicable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto: (c) interest. — an amount paid in the year or payable in respect of the year (depending upon the method regularly followed by the taxpayer in computing his income), pursuant to a legal obligation to pay interest on (i) borrowed money used for the purpose of earning income from a business or property (other than borrowed money used to acquire property the income from which would be exempt or to acquire a life insurance policy), (ii) an amount payable for property acquired for the purpose of gaining or producing income therefrom or for the purpose of gaining or producing income from a business (other than property the income from which would be exempt or property that is an interest in a life insurance policy), 67. General limitation re expenses. — In computing income, no deduction shall be made in respect of an outlay or expense in respect of which any amount is otherwise deductible under this Act, except to the extent that the outlay or expense was reasonable in the circumstances. 69. (1) Inadequate considerations.- Except as expressly otherwise provided in this Act, (a) where a taxpayer has acquired anything from a person with whom he was not dealing at arm’s length at an amount in excess of the fair market value thereof at the time he so acquired it, he shall be deemed to have acquired it at that fair market value; 96. (1) General rules.- Where a taxpayer is a member of a partnership, his income, non-capital loss, net capital loss, restricted farm loss and farm loss, if any, for a taxation year, or his taxable income earned in Canada for a taxation year, as the case may be, shall be computed as if (a) the partnership were a separate person resident in Canada; 251. (1) Arm’s length.- For the purposes of this Act, (a) related persons shall be deemed not to deal with each other at arm’s length; and (b) it is a question of fact whether persons not related to each other were at a particular time dealing with each other at arm’s length. ...

Greber and his wife in the amount of $6,692.80 for the 2002 taxation year ... Unless otherwise specified, all facts relate to the period from January 1, 2002 to December 31, 2002.   3.                   ... SCHEDULE A BREAKDOWN OF AMOUNTS PAID INTO AND ALLOCATED UNDER THE PLAN   Month Total Paid Into Plan Allocated to Allan Greber Allocated to Michelle Greber   January, 2002 $ 14,023.20 $ 8,413.92 $ 5,609.28   February, 2002    12,497.99    7,498.79    4,999.20   March, 2002    36,009.99  21,605.99  14,404.00   April, 2002    41,998.00  25,558.80  16,439.20   May, 2002    18,030.21  10,818.13    7,212.08   June, 2002    13,000.00    7,800.00    5,200.00   July, 2002    11,000.90    6,600.54    4,400.36   August, 2002    15,019.99    9,011.99    6,008.00   September, 2002    22,000.00  13,200.00    8,800.00   October, 2002    15,000.00    9,000.00    6,000.00   November, 2002    15,000.00    9,000.00    6,000.00   December, 2002     5,000.00    3,000.01    1,999.99   TOTAL $ 218,580.28 $ 131,508.17 $ 87,072.11               SCHEDULE B BREAKDOWN OF AMOUNTS PAID OUT OF THE PLAN   Month Total Paid Into Plan Allocated to Allan Greber Allocated to Michelle Greber   January, 2002 $ 14,023.20 $ 8,413.92 $ 5,609.28   February, 2002    12,497.99    7,498.79    4,999.20   March, 2002    36,009.99  21,605.99  14,404.00   April, 2002    41,998.00  25,558.80  16,439.20   May, 2002    18,030.21  10,818.13    7,212.08   June, 2002    13,000.00    7,800.00    5,200.00   July, 2002    11,000.90    6,600.54    4,400.36   August, 2002    15,019.99    9,011.99    6,008.00   September, 2002    22,000.00  13,200.00    8,800.00   October, 2002    15,000.00    9,000.00    6,000.00   November, 2002    15,000.00    9,000.00    6,000.00   December, 2002     5,000.00    3,000.01    1,999.99   TOTAL $ 218,580.28 $ 131,508.17 $ 87,072.11       [15]     The parties also entered into evidence the following exhibits:   i)        The EPSP in question which amongst other things provides for a committee to be appointed by the board of directors of the professional corporation to administer the plan and give instructions to the trustee.   ...

  [6]      The Appellant maintains that she received a salary from Aapex in the following amounts (Transcript, p. 110, lines 20 – 21):   (a)               2000- $28,000; (b)              2001- $30,000; and (c)               2002- $0 ... The following amounts were used in the respective taxation years:   (a)               2000- $273,991; (b)              2001- $343,959; and (c)               2002- $431,946 ...   [21]     The instructors paid the Appellant the following amounts for personal use of the Vehicles (the “Instructor Vehicle Fees”):   (a)               2000- $9,180; (b)              2001- $12,500; and (c)               2002- $14,920 ...

Minister of National Revenue, [1978] CTC 2002, 78 DTC 1024 Roland. St-Onge (orally: November 4, 1977):—The appeal of Mr Moses Deitcher came before me on November 2, 1977, at the City of Montréal, Québec, and the issue is whether, during his 1971 taxation year, the amount of recapture claimed by the appellant, while a resident of Canada, is subject to taxation in his hands as a non-resident of Canada, pursuant to subsections 110(1) and (5) of the Income Tax Act. ... The proceeds of disposition received by Appellant was $112,000 which was allocated as follows: $ 10,838.23 Land $101,161.77 Building 7. ...

  [2]               In determining the tax payable by the appellant for the 2001, 2002 and 2003 taxation years, the Minister relied on the following facts set out in paragraph 10 of the Reply to the Notice of Appeal:   [T ranslation]   (a) A statement of the appellant’s net worth of which a copy is hereby attached in Annex A as forming an integral part;   (b) During the 2001, 2002 and 2003 taxation years, the appellant’s family consisted of two adults and two children;   (c) For the 2001, 2002 and 2003 taxation years, the appellant and her spouse reported the following income:             YEARS     2001      2002 2003 Isabelle Gingras $7,707 $11,886 $13,083 Donald Audy ($1,734) $7,825 $24,625 Total income $5,973 $19,711 $37,708   (d) For the 2001, 2002 and 2003 taxation years, the appellant and her spouse received the following amounts of money:     YEARS        2001      2002 2003 CCTB & NCBS $4,551 $5,062 $5,148 Tax reimbursement $888 $0 $3,020 Total additional funds $5,439 $5,062 $8,168   (e) During the 2001, 2002 and 2003 taxation years, the appellant and her spouse incurred the following expenses:                                                                      YEARS      2001    2002  2003 Personal expenses $30,171 $46,853 $52,800 Provincial income tax payments $0 $287 $0 Joint federal source deductions $0 $1,378 $2,867 Joint provincial source deductions $0 $1,480 $3,359 Total expenses $30,171 $49,998 $59,026   (f) During the 2000, 2001, 2002 and 2003 taxation years, the assets and liabilities reported in the balance sheets of the appellant and her spouse were as follows:     YEARS            2000       2001 2002 2003 Total assets $ 67,227 $ 71,489 $ 68,306 $ 71,295 Total liabilities $ 129,271 $ 116,568 $ 102,359 $ 96,982 Net worth ($ 62,044) ($ 45,079) ($ 34,053) ($ 25,687)   (g) Following the evolution of the assets and liabilities described in paragraph (f) above, for the 2001, 2002 and 2003 taxation years, the assets of the appellant and her spouse increased by $16,965, $11,026 and $8,366, respectively.   (h) For the 2001, 2002 and 2003 taxation years, the expenses incurred by the appellant and her spouse leading to an increase in their assets required the following amounts:     YEARS   2001 2002      2003 Total expenses $30,171  $49,998  $59,026  Increase in assets $16,965  $11,026  $8,366 Total $47,136  $61,024  $67,392    (i) During the 2002 taxation year, the appellant and her spouse incurred a loss on personal-use property in the amount of $2,600:   (j) For the 2001, 2002 and 2003 taxation years, the discrepancies between the income and the other amounts of money of which the appellant and her spouse availed themselves and the amounts that should have been paid to cover their  expenses and to increase their assets were as follows:     YEARS   2001 2002 2003 Differential $ 35,724  $ 38,851  $ 21,516    (k) Following new submissions at the objection stage, for the 2001, 2002 and 2003 taxation years, the discrepancies described in paragraph (j) above were decreased $2,936.80, $10,788.79 and $4,050.00, respectively ...   [10]          For these reasons, the appeals from the reassessments made under the Act for the 2001, 2002 and 2003 taxation years are dismissed with costs.   ...

Minister of National Revenue, [1985] 1 CTC 2002, 85 DTC 124 Sarchuk, TCJ:—These are appeals from reassessments for the appellant’s 1979, 1980 and 1981 taxation years. ... Alessio had no previous experience in the hotel business — nor did Jackson, yet he sold his insulation business and his residence in order to obtain the capital to purchase the Didsbury. ...

January 11 and May 5, 2002   Collection notices are sent by CCRA to the Applicant.   4.       ... June 18, 2002   CCRA wrote the Applicant with instructions to appeal and the method of appealing.             6.       ... October 10, 2002                      This application is filed in the Tax Court ...

(n)     Indeed, for the 2001, 2002 and 2003 taxation years, the Appellant reported business losses from transactions involving securities other than flow-through shares:     2001 2002 2003 Business losses ($288,814) 1 ($34,746) 1 ($22,656)________________________ 1          Part of the business losses for the 2001 and 2002 taxation years results, inter alia, from the disposition of shares in Majescor Resources and/or Freewest Resources.   ...  (80 000) $8,350.00 Dec. 15, 2000 $20,000.00 $18,000.00   $2,000.00 Jan. 3, 2002 50 000 Freewest Resources Canada Inc. $13,992.21                 July 12, 2002 8 500 Majescor Resources Canada Inc. (48 265) $5,700.00 July 30, 2001 $25,000.00 $15,995.60   $9,004.40 July 22, 2002 6 000 Majescor Resources Inc. $3,580.00                 July 26, 2002 10 000 Majescor Resources Inc. $5,420.00                 Jan. 30, 2003 10 000 Majescor Resources Inc. $3,320.00                 Jan. 31, 2003 13 765 Majescor Resources Inc. $4,557.22                 May 12, 2003 300 000 Metco Resources Inc. $21,000.00 Dec. 31, 2002 $30,000.00 $24,000.00   $6,000.00 Jan. 6, 2004 133 325 Pershimco Resources Inc. $26,665.00 Dec. 15, 2003 $25,000.00 $20,000.00   $5,000.00 April 21, 2004 40 000 Metco Resources Inc. (190 590) $6,320.00 Dec. 15, 2003 $30,000.00 $12,000.00   $18,000.00 April 22, 2004 60 000 Metco Resources Inc. $8,970.00                 May 20, 2004 90 590 Metco Resources Inc. $9,964,90                   1 Flow-through shares can be purchased only upon their issuance by the company. (f)    The transactions in his personal portfolio that involved other kinds of securities of companies operating in the natural resource sector were as follows:       Date of disposition Number of shares Name of corporation Selling price Date acquired Acquisition cost Jan. 22, 2001 20 000 Freewest Resources $5,119.50 July 21, 2000 $14,400.00 Feb. 1, 2002 10 000 Mines d'Or Virginia $7,000.00 Feb. 2, 2002 $8,083.66 Feb. 23, 2001 25 000 Freewest Resources $7,179.00 Feb. 6, 2002 $7,580.50 Feb. 20, 2001 15 900 Majescor Resources $5,317.50 Feb. 1, 2002 $7,950.00 April 29, 2002 18 500 Majescor Resources $1,1825.55 June 27, 2001 $10,259.60 June 27, 2001 20 000 Freewest Resources $7,718.28 July 21, 2000 $14,400.00 April 29, 2002 13 500 Majescor Resources (15 000) $8,629.45 Sept. 4, 2001 $9,460.00 April 8, 2002 1 500 Majescor Resources $1,855.98 Sept. 4, 2001   Sept. 4, 2001 30 000 Freewest Resources $8,020.00 July 21, 2000 $21,600.00 Jan. 21, 2002 5 000 Ashton Mining Canada $19,453.60 Nov. 6, 2001 $5,830.00 Jan. 24, 2002 5 000 Ashton Mining Canada $19,800.20 Dec. 5, 2001 $8,335.59 Jan. 24, 2002 5 000 Ashton Mining Canada $19,156.52 Dec.  24, 2001 $10,960.86 April 8, 2002 3 500 Majescor Resources (11 500) $4,330.61 Dec. 27, 2001 $8,770.00 Jan. 28. 2002 15 000 Patrician Diamonds $7,050.00 Jan. 23, 2002 $7,555.00     Date of disposition Number of shares Name of corporation Selling price Acquisition date Acquisition cost April 26, 2002 5 000 Ashton Mining Canada $13,115.81 Feb. 14, 2002 $14,555.46 June 14, 2002 3 000 Ashton Mining Canada $6,354.90 Feb 14, 2002 $8,659.54 June 14, 2002 3 000 Ashton Mining Canada $6,354.90 Feb. 15, 2002 $8,305.30 Feb. 14, 2002 10 000 Majescor Resources (15 000) $13,660.16 Jan. 3, 2002 $15,898.39 April 8, 2002 5 000 Majescor Resources $6,335.05     March 25, 2002 4 000 Teck Cominco — WTS May 25, 2004 $6,610.00 March 18, 2002 $6,400.00 May 27, 2002 25 000 Freewest Resources $9,154.69 May 24, 2002 $8,750.00 May 28, 2002 1 500 Freewest Resources $555.00 May 24, 2002 $375.00 Nov. 7, 2002 17 129 Majescor Resources (20 000) $5,995.15 Nov. 6, 2002 $7,210.00 Nov. 20, 2002 2 400 Majescor Resources $1,056.00     Sept. 3, 2003 471 Majescor Resources $117.75     Feb. 14, 2003 3 113 PrimeWest Energy $79,727.31 Feb. 13, 2003 $80,159.75       Date of disposition  Number of share s Name of corporation Selling price      Acquisition date Acquisition cost Sept. 8, 2003 8 200 Ashton Mining Canada (10 000) $12,056.00   July 3, 2003 $22,080.00 Sept. 9, 2003 1 800 Ashton Mining Canada $2,566.58       Sept. 9, 2003 5 000 Ashton Mining Canada $7, 129.41   July 28, 20 03 $8,530.00 Jan. 30, 2004 10 000 Tri Origin Resources $2,700.00   Dec. 3, 2003 $3,080.00     (g)   With respect to the flow-through shares, there was no research report or financial analysis concerning the various exploration companies. ...