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Friesen v. The Queen, 93 DTC 5313, [1993] 2 CTC 113 (FCA), rev'd supra. -- summary under Inventory

.-- summary under Inventory Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Inventory In his concurring reasons for judgment, Marceau J.A. found that a single property held in connection with an adventure or concern in the nature of trade did not constitute "inventory". ...

Eskandari v. The Queen, 2007 DTC 1406, 2007 TCC 419 (Informal Procedure) -- summary under Adjusted Cost Base

The Queen, 2007 DTC 1406, 2007 TCC 419 (Informal Procedure)-- summary under Adjusted Cost Base Summary Under Tax Topics- Income Tax Act- Section 54- Adjusted Cost Base A fee that the taxpayer paid in connection with acquiring rights of an individual to purchase a condominium, with the taxpayer then acquiring the condominium, were part of the cost of acquiring the condominium. ...

Cooper v. The Queen, 2009 DTC 800, 2009 TCC 236 (Informal Procedure) -- summary under Subsection 152(1)

The Queen, 2009 DTC 800, 2009 TCC 236 (Informal Procedure)-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) The Court had the jurisdiction to consider the computation of the payment of interest on refunds payable under the Act to the taxpayer in connection with an appeal from an assessment of Part XIII tax and interest. ...

Ellingson v. Canada (Minister of National Revenue), 2005 DTC 5492, 2005 FC 1068 -- summary under Subsection 231.2(1)

Canada (Minister of National Revenue), 2005 DTC 5492, 2005 FC 1068-- summary under Subsection 231.2(1) Summary Under Tax Topics- Income Tax Act- Section 231.2- Subsection 231.2(1) Requirements were issued in connection with a joint program with the RCMP to combat organized crime, and were quashed. ...

Furman v. The Queen, 2003 DTC 723, 2003 TCC 298 (Informal Procedure) -- summary under Paragraph 8(1)(f)

The Queen, 2003 DTC 723, 2003 TCC 298 (Informal Procedure)-- summary under Paragraph 8(1)(f) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(f) A lawyer employed by a law firm was found not to be employed in connection with the selling of property or negotiating of contracts for his employer when he engaged in the wining and dining of potential clients or other promotional activities. ...

Canada Trust Co. v. The Queen, 81 DTC 5248, [1981] CTC 319 (FCTD) -- summary under Individual

The Queen, 81 DTC 5248, [1981] CTC 319 (FCTD)-- summary under Individual Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Individual The word "individual" in S.68 of the 1952 Act did not include artificial persons, such as an individual acting in her capacity of trustee, because the "individual" in that section is later referred to in connection with her spouse or family. ...

Lawrence v. MNR, 90 DTC 1491, [1990] 1 CTC 2567 (TCC) -- summary under Incurring of Expense

MNR, 90 DTC 1491, [1990] 1 CTC 2567 (TCC)-- summary under Incurring of Expense Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Incurring of Expense Fees of a notary for his services rendered in connection with the development and sale of MURBs legally were payable by the vendors of the property and not by the purchasers. ...

R. v. Anderson, 99 DTC 5536 (Sask. P. Ct.) -- summary under Section 8

.)-- summary under Section 8 Summary Under Tax Topics- Other Legislation/Constitution- Charter (Constitution Act, 1982)- Section 8 exclusion of collateral evidence The evidence collected by Revenue Canada auditors respecting the taxpayer was excluded because, from the start, the evidence had been gathered in connection with an investigation by Revenue Canada of the underground economy including, in this case, the sale of used cars. ...

Friedland v. The Queen, 89 DTC 5341, [1989] 2 CTC 79 (FCTD) -- summary under Income-Producing Purpose

The Queen, 89 DTC 5341, [1989] 2 CTC 79 (FCTD)-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose The taxpayer was able to deduct the payment by it of expenses incurred by its individual shareholder in connection with driving his BMW and Rolls downtown and to York University. ...

6 October 2006 APFF Roundtable Q. 21, 2006-0195981C6 F - Deductibility of Professional Fees - Reorg. -- summary under Legal and other Professional Fees

.-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees Fees for legal opinions and fairness opinions obtained by a public corporation in connection with a proposed offer to repurchase a portion of its shares would be capital expenditures as such fees would be incurred in connection with a reshaping of the corporation's capital structure. Similarly, fees paid for a fairness opinion obtained in connection with a proposed amalgamation of a corporation would be considered to be capital expenditures. ...

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