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TCC

Roy v. R., [1998] 2 C.T.C. 2191

Ignorance of the Act is not a valid excuse and the absence of accounting records tends to show a certain indifference which constitutes blameworthy negligence, especially in a tax system based on self-assessment by the taxpayer. 11 This carelessness and disregard of Tier tax responsibilities was confirmed by her obviously deliberate failure to report the tips she received in connection with her employment. 12 In tax law this is gross negligence which fully justifies the application of the penalties prescribed by the Act. ...
FCTD

Matembe v. Canada (Attorney General), 2023 FC 290

The one in play in this case is the requirement that there be minimum employment or net self-employment income of $5,000 in 2019 or 2020, or in the twelve-month period prior to their application for the CRB (Canada Recovery Benefits Act, SC 2020, c 12, s 2, at s. 3). [5] The sole issue before the Court concerns the employment, or self-employment of the applicant in connection with the work he claims he has performed for Uber. ...
EC decision

Brookview Investments Limited, Frank Wilson, Morris Wilson, Sydney Wilson, Ellendale Investments Limited, Bruce Finkler and Elliot L. Marrus v. Minister of National Revenue, [1963] CTC 316

All costs involved in connection with the carrying charges of such lands, excluding the mortgages hereinbefore dealt with, and the costs of development thereof shall be borne by the parties in the following proportions: The Companies of the First and Second Parts— 40% The party of the Third Part— 60% The profits shall belong to the parties hereto in the same proportions as have been outlined above, and for the purpose of calculating such profits the cost price of the lands in question shall be $2,725.00 per acre.’’ ...
EC decision

Goldwin Corlett Elgie v. Minister of National Revenue, [1963] CTC 383, 63 DTC 1242

From the foregoing facts it is apparent that the appellant had substantial funds available and as a result of knowing a great number of people from his political connections in the municipal and provincial fields, he was able to acquire, with these funds, a number of mortgages which yielded him a substantial interest income thereon and in addition a substantial yield by way of bonus or discount. ...
EC decision

James Frederick Scott v. Minister of National Revenue, [1961] CTC 451, 61 DTC 1285

His practice as a lawyer, with his special knowledge of real estate law, his connection with building contractors and real estate agents and his knowledge of the localities in which the properties covered by the agreements were located made for sound judgment on his part in carrying on his enterprise. ...
EC decision

Front & Simcoe, Limited v. Minister of National Revenue, [1960] CTC 123, 60 DTC 1081

In that connection, reference may be made to the speech of Lord Tomlin in C.I.R. v. ...
EC decision

Espie Printing Company Limited v. Minister of National Revenue, [1960] CTC 145, 60 DTC 1087

There was no illegality suggested in connection with the commissions and other items mentioned in Schedule B, and in my opinion they are deductible as well. ...
EC decision

Sterling Paper Mills Inc. v. Minister of National Revenue, [1960] CTC 215, 60 DTC 1171

In that matter the company had acquired a number of timber limits and had disposed of them in three different sales, because, although they had been acquired for the purpose of being used in the operation of its saw mill, it found that they were unusable in connection therewith. ...
EC decision

Harvey Clarke Smith v. Minister of National Revenue, [1960] CTC 391, 60 DTC 1282

According’ to the appellant, the reason for taking the title in his father’s name was that, ‘He was a business man and I was not and he looked after all the details in connection with the business.’’ ...
EC decision

Federal Farms Limited v. Minister of National Revenue, [1959] CTC 98, 59 DTC 1050

It is also established that for income tax purposes all of the expenses incurred in the seeding and cultivation of the crops destroyed were allowed as deductible operating expenses, aS well as all the expenses occasioned by the flooding and in connection with which the amount in question was spent. ...

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