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FCTD

Niemi v. The Queen, [1984] CTC 181, 84 DTC 6194 (FCTD)

Mr Niemi had been a “Big Brother” to one of Mrs Hebert’s children for several years prior to his purchase of the farm and it was because of that connection that he became familiar with the farm. ...
FCTD

Brackstone v. The Queen, 80 DTC 6060, [1980] CTC 89 (FCTD)

The Queen, 80 DTC 6060, [1980] CTC 89 (FCTD) Mahoney, J:—The only issue is whether an amount received by the plaintiff in connection with the termination of his employment was income from an office or employment as determined by the Minister of National Revenue. ...
EC decision

Canada Steamship Lines Ltd. v. MNR, 66 DTC 5205, [1966] CTC 255 (Ex Ct)

The appeal is allowed and the assessments are referred back for re-assessment so as to allow the expenditures which are the subject matter of the appeals except those expenditures which were incurred in connection with, or as a necessary incident of, replacing the boilers in the S.S. ...
FCA

Rapistan Canada Ltd. v. MNR, 74 DTC 6426, [1974] CTC 495, briefly aff'd 76 DTC 6177, [1976] CTC 296 (SCC)

RAPISTAN CANADA accepts the foregoing gift and acknowledges, covenants and agrees as follows: (a) That by reason of accepting the foregoing gift it will obtain confidential information and data disclosed to it by RAPISTAN and it will not at any time except so far as may be necessary in connection with its own rights of manufacture and sale, disclose to third persons any of the information, knowledge or data imparted or furnished to it by RAPISTAN and it will use every effort to prevent disclosures at any time of the said information, data or knowledge by its employees or others possessing or having access thereto; (b) That it will not by reason of its exercise of the rights hereby given to it obtain or claim to obtain any property rights whatsoever or wheresoever in respect to any trade name, trade mark, letters patent or applications for any such, now owned or controlled by RAPISTAN beyond the rights conferred upon it by this Deed of Gift; (c) That should trade marks covered hereby be registered by RAPISTAN under the laws of any country other than Canada, such registration and trade marks shall be the sole property of RAPISTAN, and RAPISTAN CANADA will not contest at any time in any manner, the validity thereof; (d) That should Rapistan apply for or have issued letters patent by any country other than Canada relating to any product covered by this Agreement, RAPISTAN CANADA will not contest at any time, in the manner, the validity thereof; (e) That the rights, franchises and licences acquired by it hereunder will not be transferred by it in any way without the prior consent of RAPISTAN; (f) That upon the termination of the period hereinbefore fixed it will return to RAPISTAN all blueprints, written data and information. ...
TCC

Gestion Louis Riel Inc. v. MNR, 85 DTC 550, [1985] 2 CTC 2211 (TCC)

This advance was made to Le Groupe Sigma Inc to carry out major repairs in connection with construction defects and thereby enable the company to continue in business, sell its condominiums, institute proceedings for defects in soundproofing in the amount of $270,000.00 against engineers and so make profits on the project. 10. ...
TCC

Anderson v. MNR, 92 DTC 1778, [1992] 2 CTC 2113 (TCC)

No income was generated by the trust, the manager or DRAAL in connection with the sale of trust units. ...
TCC

Cormier v. MNR, 90 DTC 1167, [1990] 1 CTC 2295 (TCC)

.: — The issue in this appeal is whether an amount of $36,950 received by the appellant in 1981 in connection with the sale of a business in 1978 is a “retiring allowance” within the meaning of subparagraph 56(1)(a)(ii) of the Income Tax Act. ...
EC decision

MNR v. Foot, 64 DTC 5196, [1964] CTC 317 (Ex Ct), briefly aff'd 66 DTC 5072 (SCC)

Additional plausibility for this view may be found in the proviso to Section 47(1) of the British Income Tax Act, 1952, determining the moral nature of the vitiating fiscal infraction; I cite: 4 Provided that where any form of fault or wilful default has been committed by or on behalf of any person in connection with or in relation to income tax, assessments, additional assessments, and surcharges on that person to income tax for that year may, for the purpose of making good to the Crown any loss of tax attributable to the fraud or wilful default, be amended or made as aforesaid at any time.’’ ...
TCC

Smith v. MNR, 89 DTC 331, [1989] 2 CTC 2069 (TCC)

Supplementary work on or in connection with the property realized. 5. ...
TCC

Cook v. The Queen, 95 DTC 853, [1995] 1 CTC 2251 (TCC)

Even if that is all she had — a right to commence legal action — I am satisfied that right, even if it only arose out of the contract between her former employer and GreatWest, that Savage, supra is sufficiently broad in its interpretation for this Court to make the connection from Cook to Great-West to Hamilton Steel Railway, her employer at the time she alleges she became disabled. ...

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