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TCC

Daoust v. The Queen, 2008 DTC 4614, 2008 TCC 316 (Informal Procedure)

MECHANICS AND PLUMBING   10.1             Equip the unit on the ground floor with new fixtures: kitchen sink, bathtub with shower enclosure, sink, toilets with insulated tank and seat   10.2             Install connections for the washer on the ground floor   10.3             Install rigid exhaust ducts leading outside for mechanical ventilation in bathrooms, range hoods and dryers                                                                        Subtotal            $4,400.00   11.                    ...
TCC

Gordon v. The Queen, 95 DTC 493, [1995] 2 CTC 2185 (TCC)

The commercial reality here was that the $400,000 expenditure represented and was laid out in connection with and in the course of the acquisition and assembly of a capital asset, the cost of which is on capital account: Firestone v. ...
TCC

Groupe Honco Inc v. The Queen, 2013 DTC 1032 [at at 149], 2012 TCC 305, aff'd 2013 FCA 128, supra

Bédard’s widow in connection with the transactions.   [21]         Mr.  ...
TCC

Dubawn Holdings Inc. v. The Queen, 94 DTC 1252, [1994] 1 CTC 2527 (TCC)

Therefore, I do not see a connection between the services promised by the appellant and any warranty or similar obligation. ...
TCC

Gainor v. The Queen, 2011 DTC 1317 [at at 1798], 2011 TCC 442

The appellant was charged and convicted of numerous counts of fraud in connection with the misappropriation of his clients’ funds. ...
TCC

Ateliers Ferroviaires de Mont-Joli Inc. v. The Queen, 2011 DTC 1358 [at at 2006], 2011 TCC 352

The equipment at issue has no connection with those two activities.   [37]          AFM owned a fleet of road vehicles that it leased to Séma ...
TCC

506913 N.B. Ltd v. The Queen, 2012 TCC 210

  [95]          Counsel for the Appellants argues that I should not make a determination with respect to relevancy until after he has presented his case to me and attempted to show me the connection between the items noted in the Affidavits and his argument ...
TCC

Chisholm v. The Queen, 99 DTC 150, [1999] 1 CTC 2498 (TCC)

Second, there must be a sufficiently direct connection between the use of the borrowed funds and the source of income. ...
TCC

Molstad Development Co. v. R., 97 DTC 913, [1997] 2 CTC 2360 (TCC)

The appellant was relieved from a liability to pay $702,467 in connection with the sale of the said property and the taxpayer was enriched by this amount. ...
TCC

Queenswood Land Associates Ltd. v. R., 97 DTC 1048, [1997] 2 CTC 2688 (TCC), rev'd 2000 DTC 6065, Docket: A-182-97 (FCA)

Counsel for the Respondent also referred the witness to the following clauses of the agreement: 2.1 Subject as hereinafter provided, First City will lend or arrange to lend to R- 104 amounts required from time to time to fund Project Costs. 2.2 R-104 will pay interest from the date of the advance on all amounts advanced in respect of the Loan and outstanding and on overdue interest thereon at the rate of 2% per annum over the Prime Rate Factor (“Prime Rate Factor” defined in the Debenture). 3.2 At each time Statements are to be delivered to First City pursuant to the provisions hereof, and after the repayment of the Loan, R-104 shall pay to First City on account of the Additional Payment, one-half (1/2) of the Net Cash Flow from the Units or the Lands or the Project, the sales proceeds of which are or are required to be reflected in the Statements then delivered or required to be delivered to First City. and Counsel for the Respondent relied more particularly on sub-clause 7-1(4): (4) expend all drawdowns under the Loan for no purpose other than in connection with the acquisition of the Lands and the construction and completion of the Project and in accordance with the plans and specifications and change orders of the Project approved by First City; Again, the witness saw nothing unusual in these clauses and only the lender’s interest to protect its advances. ...

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