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TCC

William R. Phillips v. Minister of National Revenue, [1990] 1 CTC 2372, 90 DTC 1274

.: —In 1987, the appellant was paid $10,000 by his employer in connection with the relocation of his work from Moncton, New Brunswick to Winnipeg, Manitoba. ...
FCA

Jerilynn Prior v. The Queen, [1989] 2 CTC 280, 89 DTC 5503

The motions judge was right in finding that the existence or absence of such connection was strictly a question of law to be answered in the light of the provisions of the Income Tax Act, the Constitution Acts 1867 to 1982, and the Financial Administration Act. ...
TCC

Hannibal Holdings Ltd. v. Minister of National Revenue, [1989] 2 CTC 2053, 89 DTC 345

It is equally clear from the reasons provided by the learned Judge in connection with issuing the court order dated October 15, 1984, that every effort was made to provide some stable basis for an eventual resolution of the dispute, as follows: I find that the delay in bringing the application is not adverse to the applicant and I am going to rule that it is within my power to treat the application in its entirety. ...
TCC

Earl Harris v. Minister of National Revenue, [1989] 2 CTC 2270, 89 DTC 453

Appellant's activities in connection with his stable were far too limited and on too narrow a scale for this proceeding to succeed. ...
TCC

Norman McGinnis v. Minister of National Revenue, [1989] 1 CTC 2048, 89 DTC 52

Here there was no expectation of profit and perhaps the expenses claimed in connection with the drilling operation were simply a means to write off interest which the appellant had to pay to the bank. ...
TCC

Joseph Floro v. Minister of National Revenue, [1988] 2 CTC 2319, 88 DTC 1675

In filing the reply to notice of appeal (in connection with the alternative argument noted therein), counsel for the Minister included a statement showing a calculation of possible expenses. ...
TCC

Witkor Solotorow v. Minister of National Revenue, [1988] 2 CTC 2388, 88 DTC 1667

He testified that in connection with the spruce growing venture he made enquiries at the government establishment where he buys seedlings. ...
TCC

Bert Winter v. Minister of National Revenue, [1988] 1 CTC 2191, 88 DTC 1143

., [1970] Tax A.B.C. 713; 70 D.T.C. 475, which also dealt with a construction foreman assigned to one of his employer's construction sites (subsection 5(2) referred to therein is now subsection 6(6)): It appears to follow that, while the Income Tax Act does provide relief for construction workers in subsection (2) of section 5 by permitting the exclusion from income of allowances received from their employer for away-from-home expenses, or the value thereof if provided by the employer free of charge, there is no provision whereby construction workers in the circumstances of the appellant are permitted to deduct moneys paid out of their own pockets for their personal or living expenses, even though such moneys are laid out in connection with employment accepted at some distance from their ordinary places of residence. ...
TCC

William D. Stirton v. Minister of National Revenue, [1988] 1 CTC 2298, 88 DTC 1205

Concerning the second ground of appeal, the levy of penalties for the late filing of the appellant's tax returns for the 1973 to 1978 taxation years inclusively, it is clear as I read subparagraph 152(4)(a)(i) in connection with subsections 163(2) and (3) that before the Minister may be allowed to reassess a taxpayer beyond the period of four years from the date of initial assessment the Minister has the burden of proving that the misrepresentation of the taxpayer is attributable "to neglect, carelessness or wilful default or has committed any fraud in filing the return or in supplying any information under this Act". ...
TCC

Dale Andrew Drobot v. Minister of National Revenue, [1987] 2 CTC 2098, 87 DTC 371

Drobot submitted the prescribed Revenue Canada form indicating that he was required by his employer to maintain an office, in connection with his employment responsibilities. ...

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