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Results 1351 - 1360 of 3270 for connection
TCC

Enns Brothers Ltd. v. Minister of National Revenue, [1991] 1 CTC 2024, 91 DTC 82

However, counsel for the respondent did contend that in reviewing whether any reserve" could be considered, that question must be posed in relation to the amount of the "holdback" due from John Deere in connection with the sale of the negotiable paper—the financing contract—from Enns to John Deere, and that the question could have no relation to the original sale of the equipment from Enns to the customer, which sale created the financing contract. Analysis The thrust of the appellant's evidence and argument was directed towards establishing a connection between the sale of the equipment by Enns, and the one per cent "holdback" from John Deere at issue, thereby justifying the practice of increasing the "cost of sale” by the one per cent holdback which had already been credited to sales. ...
TCC

Anthony M. Guerin and Meredith Ann Filshie v. Minister of National Revenue, [1991] 1 CTC 2634, 91 DTC 855

There were no animals kept by the appellants in connection with this farming operation. ... In connection with the latter aspect, appellant Guerin stated that when they started acquiring the above farm properties, wheat was selling at approximately $160 a metric ton. ...
TCC

McDonald v. R., [1996] 1 CTC 2585, 98 DTC 2223

Shandro’s letter of July 27, namely that: (a) upon payment of the Settlement Amount by August 22, 1988, the Bank will discharge and return all guaranties and security given by the Audias in support of the indebtedness of the Companies to the Bank; (b) upon payment of the Settlement Amount by August 22, 1988, the Bank will provide to the Audias a covenant not to sue in respect of any guarantee given by the Audias of the indebtedness of the Companies to the Bank; (c) the Consents to Venue of Foreclosure Proceedings, the Consents Order Nisi, and the Consents Order for Sale executed by the Audias will not be used in any way whatsoever by the Bank unless the Settlement Amount is not paid in full by the Audias on or before August 22, 1988; (d) the Bank agrees not to act on the Consents to Receivership executed by the Companies for a period of forty-five (45) days, commencing as of July 27, 1988, unless; (i) the Audias cease to operate the businesses conducted by the Companies, (ii) the Bank, in its sole discretion, perceives that its security is in a position of increased or increasing risk, or (iii) any term of the settlement is breached; We confirm that the Bank as of July 27 did not perceive that its security was in a position of increased or increasing risk; (e) the Bank will not object to the Audias being employed by a receiver or receiver manager of the Companies should one be appointed, and if the Audias are so employed the Bank will not object to their being paid an aggregate sum of $5,000 per month as remuneration for their services; and (f) the Bank has agreed not to sue the Audias for any deficiency which may arise in connection with foreclosure proceedings and documents referred to in paragraph (c) above. ... Appeal dismissed. 1 ’The difference between the amount of $226,000 and $225,000 represents bank charges in connection with the payment of the $225,000. 2 Mrs. ...
TCC

Whitehead v. R., [1996] 1 CTC 2637, 96 DTC 3229

(the “Act”). [1] The misrepresentations are alleged to be the failure of the appellant to report a benefit conferred upon him by 687420 Ontario Limited (“687”), in connection with the sale of shares of 568792 Ontario Limited (“568”) by him to 687. ... He then goes on to state in the following paragraph: The question of benefit or no benefit in the 1965 taxation year is, in my view, primarily a question of fact in connection with which the onus of proof was on the appellant (taxpayer). ...
TCC

Fingold v. R., [1996] 1 CTC 2772, 96 DTC 1305

Fingold outlined his family’s connections with Florida and Palm Beach beginning with his father’s interest there. ... The log showed that the persons who were entertained had business connections with Slater and Fobasco. ...
TCC

Werner J. Krampl v. Her Majesty the Queen (Informal Procedure), [1995] 2 CTC 2624

They import such meanings as "in relation to", "with reference to" or "in connection with". The phrase "in respect of" is probably the widest of any expression intended to convey some connection between two related subject matters. ...
TCC

Grant C. Werry v. Her Majesty the Queen, [1994] 1 CTC 2439, 94 DTC 1279

In his testimony, the appellant admitted that he did not keep records and books of account in connection with his business as cattle drover. ... Although it was paid to settle certain lawsuits by 21 farmers, the payment was made in connection with the Werry/Bennett partnership ("Norland"); the payment went to persons who had sold cattle to the partnership; and the cattle purchased from those 21 farmers had been sold on revenue account. ...
TCC

René Touchette v. Her Majesty the Queen (Informal Procedure), [1994] 1 CTC 2674

They import such meanings as “in relation to”, “with reference to" or “in connection with”. The phrase “in respect of" is probably the widest of any expression intended to convey some connection between two related subject matters. ...
TCC

Phyllis K. Egerton v. Her Majesty the Queen, [1994] 1 CTC 2895, 94 DTC 1500

The Federal Court of Appeal determined that the test is not whether or not the investment was subsidiary or ancillary to the taxpayer's main business, but whether the investment of funds for revenue had "some" connection with the taxpayer's business. ... The appeal by the appellant claiming eligibility of the T2211 election, in connection with the transfer of the subject shares by the appellant to her son in 1987, is dismissed. ...
TCC

Brenda Hughes v. Her Majesty the Queen (Informal Procedure), [1993] 2 CTC 2894

The issue involves certain amounts received by the appellant in 1990 in connection with her employment at a place called Rocky Mountain Bed and Breakfast in the town of Banff, in the Province of Alberta. ... This meant that Tony performed more than 50 per cent of the duties in connection with the bed and breakfast, and so they changed their arrangement. ...

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