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Results 4261 - 4270 of 11351 for consideration
FCA

Muszka v. The Queen, 94 DTC 6076, [1994] 1 CTC 365 (FCA)

Notwithstanding the provisions of the Act out of which an appeal arises, the Court, in hearing an appeal referred to in section 18, is not bound by any legal or technical rules of evidence in conducting a hearing for the purposes of that Act, and all appeals referred to in section 18 shall be dealt with by the Court as informally and expeditiously as the circumstances and considerations of fairness permit. ...
FCA

Roseland Farms Ltd. v. The Queen, 96 DTC 6041, [1996] 1 CTC 176 (FCA)

(as he then was) stated for the majority, at page 183 (D.L.R. 400): The rationale of this last-mentioned consideration has been eloquently expressed by Bentham in these terms: “In the darkness of secrecy, sinister interest, and evil in every shape have full swing. ...
EC decision

Atwater Western Corp. v. MNR, 70 DTC 6312, [1970] CTC 472 (Ex Ct)

In my view, it does not become any the less a capital transaction when the real consideration for the shares is a contribution to the company of property required as a capital asset for the proposed business of the company. ...
TCC

Hennig v. The Queen, 2012 DTC 1152 [at at 3353], 2012 TCC 141 (Informal Procedure)

In determining the Appellant’s tax liability for the tax liability of the Corporation, the Minister made the following assumptions of fact:               (a)        Hennig Trucking Ltd (the “Corporation”) was a trucking company;               (b)        The Appellant’s husband died December 9, 1992;   (c)        The Appellant continued to operate the business of the Corporation for approximately 10 years;   (d)        The Appellant was the 100% shareholder in the Corporation for the fiscal years of March 31, 2001 and March 31, 2002   (e)        The Corporation ceased operating in 2002 and a dividend of $108,000 was paid to the Appellant;   (f)         At the time that the Corporation paid the dividend to the Appellant it was indebted to the Minister for corporate taxes as set out in attached Schedule A; and   (g)        No consideration was provided by the Appellant for the dividend of $108,000.   ...
FCTD

Stephens v. The Queen, 77 DTC 5418, [1977] CTC 590 (FCTD)

That this was an obiter finding is clear from the introduction to the paragraph on page 4 of the reasons for judgment [[1977] CTC 488 at 490] which reads: While what has been said above is sufficient to dispose of plaintiff’s present application by dismissing same, subparagraph (c)(iii) (supra) does indicate that one of the matters which the Court should take into consideration is whether there are reasonable grounds for objecting to or appealing from the assessment. ...
TCC

Roud Estate v. The Queen, 2013 DTC 1057 [at at 309], 2013 TCC 36 (Informal Procedure)

I understand that such an application has been made and would expect it to be given appropriate consideration in these circumstances.   ...
TCC

Jennings v. The Queen, 2015 DTC 1117 [at at 743], 2015 TCC 96 (Informal Procedure)

In the application, the appellants mention that the property had been assessed property tax since 1980 as a three-unit building, and that the City had informed the appellants that the property enjoyed non-conforming rights. [8]              Consideration of the application was delayed for several years through no fault of the appellants and the existing use of the property was permitted during this period because an application was pending. [9]              The appellants were required to make a new application in 2010, which they did with the assistance of a planning consultant. ...
FCA

Humanics Institute v. Canada (National Revenue), 2015 DTC 5012 [at at 5542], 2014 FCA 265

While the appellant has attempted to distinguish Fuaran on the basis that other considerations were at play in that case, the proposition for which it stands is unaffected. ...
FCTD

Chequer v. The Queen, 88 DTC 6169, [1988] 1 CTC 257 (FCTD)

It is clear that, even when taking into consideration his wife's salary as well as his own, he could not have afforded the 48-foot cruiser for his own use exclusively as a pleasure craft. ...
FCTD

The Queen v. Jeromel, 86 DTC 6370, [1986] 2 CTC 207 (FCTD)

Since the hearing I have reviewed the collective agreement entered in evidence and have considered the cases submitted by counsel and have come to the conclusion that the defendant, during the period relevant to the consideration of this matter, was not employed by the Board and accordingly was not required to carry out any duties of employment. ...

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