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FCTD

Automatic Toll Systems (Canada) Ltd. v. MNR, 74 DTC 6060, [1974] CTC 30 (FCTD)

Only two paragraphs of this letter are relevant to this appeal; they read as follows: It is agreed that you will act as our representative in connection with business undertaken with the Quebec Autoroute Authority for which a commission of 10% will be paid to you for performing the services ordinarily performed by a manufacturer’s representative. ...
TCC

Jennings v. The Queen, 2015 DTC 1117 [at at 743], 2015 TCC 96 (Informal Procedure)

I understand that the appellants tried to avoid having a new application in 2010, but the City required them to go through a new process. [17]         Throughout this whole period, the use of the property did not change. [18]         In my view, the expenditures should be viewed as ordinary expenditures incurred in connection with the day-to-day management of the rental property. ...
TCC

Delancy v. The Queen, 2004 DTC 2907, 2004 TCC 465 (Informal Procedure)

Delancy was reimbursed for travel expenses incurred in connection with games away from his home clubs and was otherwise required to pay his own expenses. [3]      In computing income for the 2000 taxation year, Mr. ...
TCC

Loewig v. The Queen, 2006 DTC 3500, 2006 TCC 476 (Informal Procedure)

Loewig proceeded with only one issue, the deductibility of $1,391.00 in legal fees incurred in connection with a court proceeding in which he sought to have stopped the continued deduction of support payments by the Family Responsibility Office ("FRO"). [2]      The facts are quite straightforward. ...
FCTD

Hadler Turkey Farms Inc. v. The Queen, 86 DTC 6013, [1986] 1 CTC 81 (FCTD)

The issue then becomes whether, given the absence of any time period specified in section 28, the taxpayer is entitled to exercise the option to file on the cash basis, at any time. 28.(1) For the purpose of computing the income of a taxpayer for a taxation year from a farming business, the income from the business for that year may, if the taxpayer so elects, be computed in accordance with a method (in this section referred to as the “cash” method) whereby the income therefrom for that year shall be deemed to be an amount equal to the aggregate of (a) all amounts that (i) were received in the year, or are deemed by this Act to have been received in the year, in the course of carrying on the business, and (ii) were in payment of or on account of an amount that would, if the income from the business were not computed in accordance with the cash method, be included in computing income therefrom for that or any other year, and (b) such amount, if any, as may be specified by the taxpayer in respect of the business in his return of income under this Part for the year, not exceeding the fair market value at the end of the year of livestock (other than animals included in his basic herd within the meaning assigned by section 29) owned by him at that time in connection with the business minus the aggregate of (c) all amounts that (i) were paid in the year, or are deemed by this Act to have been paid in the year, in the course of carrying on the business, and (ii) were in payment of or on account of an amount that would, if the income from the business were not computed in accordance with the cash method, be deductible in computing income therefrom for that or any other year, and (d) the amount, if any, specified by the taxpayer in respect of the business in accordance with paragraph (b) in his return of income under this Part filed for the immediately preceding taxation years; and minus any deductions for the year permitted by paragraphs 20(1)(a) and (b)*. [1] The income tax system is based on annual self-assessment. 150. (1) A return of the income for each taxation year in the case of a corporation and for each taxation year for which a tax is payable in the case of an individual shall, without notice or demand therefor, be filed with the Minister in prescribed form and containing prescribed information. ...
FCTD

Dobell v. The Queen, 77 DTC 5316, [1977] CTC 458 (FCTD)

Exhibit 2 was a statement of material facts filed with the Vancouver Stock Exchange in connection with the offering of Dison International shares to the public. ...
FCA

Travel Just v. Canada Revenue Agency, 2007 DTC 5012, 2006 FCA 343

  [14]            In contrast, there is no indication in the material before us that Travel Just has any connection with Québec or has plans to operate there. ...
FCTD

Mohl v. The Queen, 89 DTC 5236, [1989] 1 CTC 425 (FCTD)

He owned no buildings or land for use in connection with the farming activity of breeding and racing horses. ...
FCA

Canada v. Quigley, 2009 DTC 6206, 2009 FCA 287

In the same Order, the Judge allowed the Crown’s motion to quash Mr Quigley’s appeal with respect to the 2002 and 2003 taxation years. [2]                Mr Quigley filed no Notice of Appearance in response to the Crown’s Notice of Appeal from the Judge’s Order and has not submitted a memorandum of fact or law, nor any other documents, in connection with the appeal. ...
FCTD

T & S First Choice Renovations Limited v. Canada Revenue Agency, 2012 DTC 5152 [at at 7377], 2012 FC 1146

The factors were examined and a rational conclusion was reached on each: ·                      There was no causal connection between Mr. ...

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