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TCC

Donald Woodside v. Her Majesty the Queen (Informal Procedure), [1993] 2 CTC 2348

., [1991] 1 C.T.C. 2529, 91 D.T.C. 720 which, although not binding, is a judgment which, as a matter of practice, is to be given substantial consideration. ...
BCSC decision

Deputy Minister of National Revenue v. Gerald Donald Jackman, [1992] 2 CTC 160

Slight omissions which would have no real bearing on the merits of the matter do not constitute any breach of the petitioner's duty to disclose all material considerations. ...
TCC

Storey Group Homes Limited v. Minister of National Revenue, [1992] 2 CTC 2052, 92 DTC 1295

In consideration for all of this, the appellant receives payments from the children's aid societies, the bulk of which payments are calculated on a per-child-per-day basis. ...
TCC

Discovery Research Systems Inc. v. Her Majesty the Queen, [1992] 1 CTC 2394

Cases are to be dealt with as expeditiously as circumstances and considerations of fairness and justice permit. ...
TCC

Benedict J. Kuzmicz v. Minister of National Revenue, [1992] 1 CTC 2727, 92 DTC 1331

Taking all of these facts into consideration, the Court can only come to the conclusion that the appellants primary intention when he entered into the handwritten agreement on September 5,1975 to purchase the property was to develop the property and hold the same as inventory. ...
TCC

Vista Wood Estates Limited v. Minister of National Revenue, [1989] 2 CTC 2376, 89 DTC 567

However, that consideration is of no assistance in this case because it was not shown that payments of the sort now in question were ever exempted by the provisions of the Canada-U.S. ...
WestminsterCountyCt decision

The Queen v. Betterest Vinyl Manufacturing Ltd. And Jesse Allan Holmes, [1989] 1 CTC 197

After consideration, I am of the opinion that even if the Crown can “switch hats" the new hat must fit the intent and requirements of the Income Tax Act, subsection 231(9). ...
TCC

Anne E. Lawrick v. Minister of National Revenue, [1989] 1 CTC 2028, 89 DTC 14

Subsection 21(1) of the Matrimonial Property Act provides that: 21.(1) Upon application by a spouse for the distribution of matrimonial property, the Court shall, subject to any exceptions, exemptions and equitable considerations mentioned in this Act, order that the matrimonial property or its value be distributed equally between the spouses. ...
TCC

Willis S. McLeese v. Minister of National Revenue, [1989] 1 CTC 2201, 89 DTC 157

In 1977 consideration was given to the breeding and raising of horses. ...
TCC

Franklin Dale Earl v. Minister of National Revenue, [1989] 1 CTC 2323, 89 DTC 221

Subsection 50(1) reads: 50.(1) For the purposes of this subdivision, where (a) a debt owing to a taxpayer at the end of a taxation year (other than a debt owing to him in respect of the disposition of personal-use property) is established by him to have become a bad debt in the year, or (underlining mine) (b) a share of the capital stock of a corporation (other than a share received by a taxpayer as consideration in respect of the disposition of personal-use property) is owned by the taxpayer at the end of a taxation year and the corporation has during the year become a bankrupt (within the meaning of subsection 128(3)), the taxpayer shall be deemed to have disposed of the debt or the share, as the case may be, at the end of the year and to have reacquired it immediately thereafter at a cost equal to nil. ...

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