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TCC

Charron v. R., [1998] 2 C.T.C. 2240

The wearing of appropriate clothing is thus mandatory for counsel to be “heard” in courts and so to represent clients. 19 Counsel for the respondent admitted that the penalty claimed may have no basis in the circumstances but argued that clothing is not deductible under the Income Tax Regulations (“the Regulations”). 20 There is in s. 1100 of the Regulations the “catch-all” clause contained in Class 8 with a deduction (20 percent) allowed for the cost of a “tangible capital property” [immobilisations matérielles] not listed but used in connection with income-producing property. ...
TCC

Benson Investments Ltd. v. R., [1998] 2 C.T.C. 2434, 98 D.T.C. 1367

In computing income for his 1991 taxation year, Benediktson claimed a deduction for an allowable business investment loss in the amount of $121,830 from the disposition of land and buildings, which arose in connection with the $620,000 debt owing to him from Investments, on the basis that it had become a bad debt in that year. ...
EC decision

C. B. Jean Lorenzen v. Minister of National Revenue, [1964] CTC 138, 64 DTC 5091

Although the housekeeper answered the telephone and recorded messages for the appellant, this was incidental to her housekeeping duties and in no way was she directly employed in connection with the appellant’s real estate selling. ...
EC decision

Minister of National Revenue v. Premium Iron Ores Limited, [1964] CTC 202, 64 DTC 5131

The amounts in issue in the cross-appeal are legal expenses incurred by the respondent, being $12,317.36 paid in 1951, and $8,514.16 in 1952, in connection with this claim by the United States Internal Revenue Service, which claim ultimately was successfully resisted. ...
EC decision

J. & R. Weir, Limited v. Minister of National Revenue, [1964] CTC 529

The supplementary dues levied in connection with the four years’ period amount to $5,207.62 and were imposed, so the respondent contends in para. 10 of his Reply, on the assumption that ‘‘the appellant’s dealings in government bonds were a venture in the nature of trade within the meaning of section 139 (1) (e) of the Income Tax Act’’. ...
EC decision

Minister of National Revenue v. George Lindsay Bower, [1959] CTC 107, 59 DTC 1055

That return is not before me but I record the transaction as I shall have to refer to it later in connection with the sale of 4420 Dewdney Avenue. ...
EC decision

Minister of National Revenue v. Bonaventure Investment Co., Ltd., [1962] CTC 160, 62 DTC 1083

No complications occurred in connection with the first block of 50 lots bought outright, legal ownership of which was regularly delivered to Bonaventure Investment, this company then proceeding to build 50 bungalows and disposing of the entire development. ...
QCQC decision

Rene Lafleur v. Minister of National Revenue Et At., [1966] CTC 733, 66 DTC 5441

See in this connection our recent decision in Richstone Bakeries Ltd. v. ...
EC decision

William G. Briggs v. Minister of National Revenue, [1958] CTC 11, 58 DTC 1006

I cannot admit of so restrictive an interpretation which, if allowed, would provide an even easier way of thwarting the normal functioning of the Act than was pointed out above in connection with periodical dissolutions of partnership. ...
EC decision

Minister of National Revenue v. Caine Lumber Company, Ltd., [1958] CTC 132, 58 DTC 1086

Then, a consequent application of Section 20(3) (a) thrusts upon Caine Lumber Company the quality of taxpayer and eliminates all doubt as to this timber land becoming not merely depreciable but also depreciated property from 1952 onwards, in connection to which respondent filed an allowance claim in the sum of $3,376.41. ...

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