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Results 1 - 10 of 430 for connection
EC decision
Herbert Wallace Losey v. Minister of National Revenue, [1957] CTC 146, 57 DTC 1098
It is the benefit and advantage of the good name, reputation and connection of a business. ... While this business connection which the appellant had was an asset its transferable value could not be otherwise than very small. ... Moreover, the connection which he had was largely personal to himself and his two salesmen. ...
EC decision
Estate of Dame Adolorata Fabi v. Minister of National Revenue, [1963] CTC 403, 63 DTC 1253
Also a second schedule, marked ‘‘ Appendix 1 ’ of purchases and sales covering four pages which were made jointly by Samuel Fabi and his mother in connection with lots 4 and 5 (Brault Farm). ... No evidence was offered as to the extent to which the late Adolorata participated with her son in the real estate activities in connection with the acquisition, subdivision and subsequent sale of lots in 1955 and 1956 as described in Appendix 1. ...
EC decision
Sterling Royalties Limited v. Minister of National Revenue, [1942] CTC 133
The appeal is confined to paragraphs two and three set forth in what is called "‘Statement of Facts and Recapitulation”, a document served upon the Minister of National Revenue by the appellant and which is found in the documents transmitted to the Registrar of this Court in connection with this appeal. ... The proper assessment should have allowed deduction for expenses in connection with drilling and other development costs. ...
EC decision
St. Charles Hotel Limited v. Minister of National Revenue, [1952] CTC 312, 52 DTC 1177
In this connection, see the decision of Cameron, J. in Vancouver Towing Company Limited v. ... Charles Hotel Limited Standard Profits Claim In connection with the 8.P. 1 Claim of St. ... It is therefore unnecessary to deal with the cases and authorities cited by him in this connection. ...
EC decision
Robert B. Curran v. Minister of National Revenue, [1957] CTC 384, 57 DTC 1270
This amount never was disbursed by either of the three companies with which Curran had business connections during 1951. ... Brown’s only object was the enlistment for his companies of Curran’s reputed experience, capabilities and connections. ... The appellant predicated his first line of attack on a total lack of employer-employee connection between himself and Brown. ...
EC decision
Minister of National Revenue v. Dame Rene Fortin, Testamentary Executrix of the Estate of Rene Fortin, [1970] CTC 521, [1970] DTC 6339
In calculating the amount of $35,900 owing to him, no allowance was included for the amount. to be earned in connection with the Papineau Métro Station, the amount of $3,000 appearing for Métro in the said ‘schedule being for services in connection with the tube under the station for which the work was completed. and payment made (evidence of Jean Amyot before Tax Appeal Board, Exhibit C-l, p. 26). ... The first of these was the sum of $11,110 which the deceased received in 1964 as his share of profits for work done in connection with the Sogefors contract which was completed in 1963. ... This did show amounts totalling $13,900 to be collected by him in connection with the Sogefors contract which sums it is admitted he collected. ...
EC decision
Dominion Dairies Ltd. v. MNR, 66 DTC 5028, [1966] CTC 1 (Ex Ct)
It is the benefit and advantage of the good name, reputation, and connection of a business. ... Mitchell (1911-12), 3 O.W.N. 495 at pp. 428 et seq. where he said: ‘ ‘ As stated in Lindley on Partnership, at p. 476, the expression ‘goodwill’, when applied to a business, ‘is generally used to denote the benefit arising from connection and reputation, and its value is what can be got for the chance of being able to keep that connection and improve it.’ ... (Lord Eldon) Goodwill regarded as property has no meaning except in connection with some trade, business, or calling. ...
EC decision
Minister of National Revenue v. Canada Trust Company (Estate or Mary Viola Maine), [1964] CTC 179, 64 DTC 5128
The first part is a trust “to permit’’ the testator’s wife the use of a certain residence and the second part is an instruction with reference to payment of certain expenses in connection with that residence. The second part reads in part: “I do instruct my executors and trustees to pay all expenses in connection with the carrying on and maintenance of such residence out of the capital of my estate.’’ ... In that connection, I should say that I have not overlooked the argument of counsel for the Minister that there is a dominating desire by the testator, appearing in his will, that his wife should not suffer from want. ...
EC decision
Gunnar Mining Ltd. v. Minister of National Revenue, [1965] CTC 387, 65 DTC 5241
This latter regulation is the deduction permitted. under Section 11(1) (c) ‘‘in respect of (i) borrowed money used in connection with, or used for the purpose of acquiring property used in connection with, or (ii) an amount payable for property used in connection with... production of... industrial minerals...’’. ... Parkinson or any other witness to prove this; indeed no connection between these transactions was established at all. ...
EC decision
Minister of National Revenue v. United Auto Parts Limited, [1961] CTC 439, 61 DTC 1259
The connection, if any, between the shares purchased and the proceeds of the debentures to the extent of $988,029 and the consequences which follow in either event constitute the main issues in the present case. ... The new evidence was introduced by the appellant for the purpose of disproving the respondent’s contention that the debentures issued in 1947 and subsequent interest paid thereon had no connection with the purchase of the newly acquired shares of the subsidiary companies and that they were part-payment of one continuing transaction. ... The provisions of Section 12(1) (c) with which we need be concerned read: ‘ No deduction shall be made in respect of an outlay or expense to the extent that it may reasonably be regarded as having been made or incurred... in connection with property the income from which would be exempt.’’ ...