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SCC

Minister of National Revenue v. Edgeley Farms Limited, [1969] CTC 313, 69 DTC 5228

I have no doubt that, if the guiding mind of the appellant were to have frankly answered questions at the time of acquisition, he would have agreed that the appellant might itself, at an appropriate time, erect on the land buildings suitable for the developing neighbourhood, with a view to renting them or selling them; he would also have agreed that, if the right opportunity or opportunities arose, the appellant might sell some or all of the property, and he would also have agreed that a really attractive bare land leasing proposal would receive careful consideration by the appellant. ...
EC decision

Isadore Weinstein v. Minister of National Revenue, [1968] CTC 357, 68 DTC 5232

On October 6, 1959 the appellant sold all his interest in the said parcel of land for a total consideration of $53,750. ...
BCSC decision

In Re Modern Film Distributors Ltd. Et Al., [1968] CTC 549, 68 DTC 5349

Making such clearly unfounded claims of privilege can only reduce the time available for consideration of documents in respect of which a claim for privilege might succeed. ...
T Rev B decision

Pounder v. Minister of National Revenue, [1975] C.T.C. 2264, 75 D.T.C. 205

The appellant, who ably argued his own case, contended that he is entitled to claim under subsection 27(4) of the Act which reads as follows: 27. (4) For the purpose of paragraph (c) of subsection (1), where medical expenses became payable by a taxpayer or his legal representatives during a period of 12 months referred to in subparagraph (i) or (ii) thereof and were paid after that period on behalf of the taxpayer or his legal representatives pursuant to a contract of insurance in respect of medical expenses for which insurance the taxpayer had paid premiums or other consideration, the expenses may be deemed to have been paid when they became payable. 5 The appellant submitted that the Alberta Health Care Insurance Commission is the agent for its subscribers and did in fact pay to the doctor the $104 of medical costs in question. ...
T Rev B decision

P W Lavack Co. v. Minister of National Revenue, [1975] C.T.C. 2365, 75 D.T.C. 283

Minister of National Revenue, [1975] C.T.C. 2365, 75 D.T.C. 283 A J Frost: 1 This is an income tax appeal for the appellant's 1971 and 1972 taxation years, wherein the Minister of National Revenue disallowed the following items: (a) Mortgage interest in the sum of $3,857.64 and life insurance costs of $452.47 in respect of its 1971 taxation year, and (b) Legal costs of $800 in respect of its 1972 taxation year. 2 In 1971 the appellant purchased all the outstanding shares of Chapels Limited from Capasu Holdings Ltd by agreement dated October 28, 1971 for a total consideration of $238,006.89. ...
T Rev B decision

Richmond Plywood Corp. v. Minister of National Revenue, [1975] C.T.C. 2196, 75 D.T.C. 147

In 1969 it availed itself of the provisions of Income Tax Regulation 1100(1)(e) and deducted the sum of $16,875.40 pursuant to the provisions of the said Regulation and Schedule C. 7 The question to determine here is: Was this consideration for the assignment of a depreciable capital asset within the meaning of the Income Tax Act and the pertinent regulations thereto, or was this a capital outlay to acquire a preferred position to obtain timber sales licences in the future? ...
TCC

Morin v. R., [1998] 2 C.T.C. 2626

Is this not taken into consideration at all? If we look at the situation differently, that is, if we suppose that there was no joint custody and that my four children lived with me during the first 26 consecutive weeks of the year, you could not then deny the fact that they were wholly dependent on me during this period. ...
TCC

Lawrence v. R., [1998] 2 C.T.C. 2716

Legal costs to prosecute and to defend most tort, contract and other civil claims arising in the ordinary course of business will generally be deductible. 9 The Appellant also contends that he was forced to settle because of financial considerations. ...
TCC

Duguay v. R., [1997] 3 C.T.C. 2212

Where there is inconsistency between the content of such a brochure and the text of the Act, the Act alone must be taken into consideration. 15 Furthermore, I believe it is important to note that the brochure to which the appellant referred does not support his claims. ...
TCC

Bronny v. R., [1997] 3 C.T.C. 2066

The property was sold for $750,000.00 being the amount of the first mortgage on this property which 815360 Ontario Inc. assumed in consideration of the purchase price. ...

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