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T Rev B decision

Doris Lillian Gadsden v. Minister of National Revenue, [1983] CTC 2132, 83 DTC 127

Moreover, in R v Bates and Another, 1952 All ER 842, it is explained that the principle of interpretation with respect to the title of an act is..to make general provision for preventing fraud in connection with dealings in investments.. and is said to apply to the cross-heading “General provisions for the prevention of fraud”. ...
T Rev B decision

Bio-Test Laboratory Inc v. Minister of National Revenue, [1983] CTC 2348, 83 DTC 295

See also s 139(1)(ae) of the Income Tax Act which includes as “personal and living expenses” and therefore not deductible for tax purposes, the expenses of properties maintained by the taxpayer for his own use and benefit, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit. ...
T Rev B decision

William Greenspoon, Mid-North Iron & Metals Limited v. Minister of National Revenue, [1982] CTC 2163, 82 DTC 1181

Ainsworth: Mid-North Iron & Metals Limited and William Greenspoon We are counsel for the above in connection with charges that have been laid against them under the Income Tax Act on which it is anticipated that our client will be tried during the week of 3 April, 1978. ...
T Rev B decision

James R Leslie v. Minister of National Revenue, [1982] CTC 2233, 82 DTC 1216

The Moldowan (supra) quotations above were made in connection with a “farming business” appeal, and as it may be seen from James R Zavitz v MNR, [1978] CTC 3021; 78 DTC 1730, and from The Queen v James R Zavitz, [1981] CTC 17; 81 DTC 5007, there is a feature about the “business of farming” in which encouragement and flexibility is permitted to a taxpayer in getting established, or in surmounting economic fluctuation — by virtue of the “restricted farm loss provisions” of the Act, which is not permitted to that degree in other business ventures. ...
T Rev B decision

Peter Rawsthorne v. Minister of National Revenue, [1981] CTC 2187, 81 DTC 116

In connection with the imposition of a penalty, Mr Raymond Alphonso Di Martile, Field Auditor for Revenue Canada, presented his “Penalty Recommendation Report’’ as Exhibit R-1. ...
T Rev B decision

Cfto Tv Limited v. Minister of National Revenue, [1980] CTC 2052, 80 DTC 1066

It is to be recalled that when the appellant claimed its share of the operating losses of the partnership as a deduction in computing its income in 1971 to 1974 inclusive, it also reported a 1974 taxable capital gain of $1,676,243 in connection with the sale of its interest in CKLW TV to St Clair. ...
T Rev B decision

Wynndel Logging Co Ltd, Wynndel Lumber Sales Ltd, Hallmark Lumber Ltd, Celcrest Timber LTD v. Minister of National Revenue, [1980] CTC 2141, 80 DTC 1125

In connection with Rose Wigen’s right to vote with respect to control, reliance was of course placed on the case of Buckerfield’s Limited et al v MNR, [1965] 1 Ex CR 299; [1964] CTC 504; 64 DTC 5301, the decision of Jackett, P (as he then was) with respect to control, and two articles of the articles of association of Logging; namely, articles 29 and 55. ...
TCC

Hallbaurer v. R., [1997] 1 CTC 2428, [1997] DTC 767

“by virtue of”... require a strong causal connection. I find little or no difference between the meanings of the phrases “because of’, “as a consequence of’ and “by virtue of’. ...
TCC

Lorenz v. R., [1997] 1 CTC 2484, 97 DTC 756

She did not question the origin of the refund or consider it might have a connection to the business loss. ...
FCTD

Young v. R., [1998] 1 CTC 196, 98 DTC 6028

Wong said that the Fairness Committee did not want any connection between the Fairness Committee decision and the settlement of the Notice of Objection. ...

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