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T Rev B decision

Lambert & Grenier Inc v. Minister of National Revenue, [1979] CTC 2929, 79 DTC 486

. $ 632.00 3. 26/10/73 Project: 434-2906-3 Warwick Material laid for conduit and box in con crete, connection of shacks, trailer and pump for this project. $3,979.62 4. 12/11/73 Project: 320-2908-2 Quebec City signals Repair electrical conduit at five different places, excavation, compacting and chang ing material. $4,252.16 5. 23/11/73 Project: 320-2913-2 Quebec City Material laid and time to lay conduits in concrete bases for signals—change two wire wheels and make repairs at input caused by short circuit. $2,561.65 6. 26/11/73 Project: 674-2907-2 Lachute Installation of a temporary input of 100 amperes, collection of trailer and pump, repair block, four lights, 1500 watts. $ 493.60 $18,745.47 Each of these descriptions of the work is followed by description’s of the material used, the number of hours and the number of workers, transportation and meals, and the cost applicable to each item. 3.22 All these invoices are referred to in a document (Exhibit I-2) seized at the residence of Mr J B Grenier, one page of which (filed at p 28 of Exhibit 1-1) is titled “Withdrawn in 1973”. ...
FCTD

Her Majesty the Queen v. Gertrude Veronica Hewitt, David Albert Bowles, John Alexander Mace and the Canada Trust Company as Executors and Trustees Under the Last Will and Testament of John Cyril Hewitt, Deceased, [1978] CTC 314, 78 DTC 6123

It might be mentioned in passing, although the decision of the case does not depend on it, that it is evident that a monthly payment of $750 even if escalated according to the cost of living index, together with the provision of a house with all expenses in connection with it paid out of the estate, would not seem to be sufficient to in any way maintain a standard of living equal to that which the widow enjoyed prior to the testator’s death when it is considered that the aggregate net value of the property passing on his death was over a million and three-quarters dollars, which even on a very conservative basis would be anticipated to yield an annual income of not less than $150,000. ...
FCTD

Her Majesty the Queen v. Louis Bisson, [1978] CTC 332, 78 DTC 6224

This was refused as it is the responsibility of the Court to determine the issue on the basis of the documents produced in evidence and no expert evidence is required nor should be permitted in this connection. ...
FCTD

S & S Properties LTD v. Her Majesty the Queen, [1978] CTC 412, 78 DTC 6294

He had had difficulties with his wife and she had put a lien on the property to protect her interest and as a result of this Imperial Oil Limited from whom he had borrowed in connection with the purchase of the property would not allow him to make further drawings on the loan so he sold it. ...
T Rev B decision

Mary Assaly, Thomas C Assaly, Ernest Assaly, Louis C Assaly, Laureen Assaly, Trendsetter Developments Limited, Assaly Construction Limited and Gloria Assaly v. Minister of National Revenue, [1978] CTC 2082, 78 DTC 1086

In my view none of the legal or liquidators’ expenses are chargeable to income and the appeals in this connection are dismissed. ...
FCTD

Mainland Crystal Glass LTD v. Her Majesty the Queen, [1977] CTC 117, 77 DTC 5080

To carry on the trades or businesses of glass manufacturers, engineers, installers, repairers and workers, and to do all things incidental to and in connection with the said trades or businesses. ...
T Rev B decision

Harold Duncan v. Minister of National Revenue, [1977] CTC 2004, 77 DTC 6

I cannot see, in the circumstances, any badges of trade in connection with the buying and selling of this property, and so I hold that, in so far as the assessment appealed from adds profit on the sale of this lot to the income of the appellant, the appeal is allowed. ...
T Rev B decision

Ferdinand Thiessen v. Minister of National Revenue, [1977] CTC 2079, 77 DTC 59

As to paragraph 4, the parties were the owners of a parcel of land of about 5 acres under an agreement for sale, on which there was a 3-bedroom bungalow together with two buildings used in connection with the raising of broilers. ...
T Rev B decision

Ralph G Mersereau v. Minister of National Revenue, [1977] CTC 2412, 77 DTC 290

The sale of the shares was duly completed in April 1973, and the appellant no longer had any connection with the company although, as required by the agreement, he remained an employee until June 30, 1973. ...
T Rev B decision

Wallace R Brunelle and Peter Brunelle v. Minister of National Revenue, [1977] CTC 2506, 77 DTC 326

By agreement with K & K Manufacturing Inc dated November 1967 (Exhibit R-4), Canadian Nurs-Ette obtained a franchise and were given, for a period of 10 years, the exclusive right to use the trade name “Nurs-Ette” in connection with the sale of the livestock milk product and the automatic calf-feeder manufactured by K & K Manufacturing Inc. ...

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