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TCC

Myron Pasnak v. Minister of National Revenue, [1984] CTC 2719, 84 DTC 1677

Some of these, counsel for the Minister did put forward for the Court’s consideration. ...
TCC

Louis M Gabrielle v. Minister of National Revenue, [1984] CTC 2722, [1984] DTC 1635

Any other interpretation would indeed leave open for consideration the ultimate date referenced by counsel for the appellant — “perhaps it was his birth”. ...
TCC

Eric Dunlop v. Minister of National Revenue, [1984] CTC 2837, 84 DTC 1768, [1984] CTC 2841

The purchaser of sales No 2 was said to have had subdivision intentions for his property as a future consideration. ...
TCC

Kenneth B Bright v. Minister of National Revenue, [1984] CTC 2988, 84 DTC 1804

The learned Justice indicated clearly that a wider interpretation can be given to the expression ‘‘a reasonable expectation of profit” and, in my opinion, the intent of Parliament and the reasons it provided for the deduction of restricted farm losses are very important considerations in deciding the issue. ...
TCC

Clifford Olson, Phyllis Olson v. Minister of National Revenue, [1984] CTC 3029, 84 DTC 1826

He apparently gave no consideration to the prospect that the repetitive method of such repayments could lead to the assertion of the Minister, (supra), that there was a “series” involved. ...
T Rev B decision

F W Woolworth Co Limited v. Minister of National Revenue, [1983] CTC 2075, 83 DTC 85

The same considerations apply here. For the foregoing reasons, the appeals will be dismissed. ...
T Rev B decision

Valley Vu Realty (Ottawa) Limited v. Minister of National Revenue, [1983] CTC 2238

As part of the consideration for the purchase, the appellant took back from NDM Holdings a mortgage for $1,300,000. ...
T Rev B decision

Victor Gusso, Jean Gusso v. Minister of National Revenue, [1983] CTC 2266, 83 DTC 226

(c) On consideration of the Notice of Objection, the Minister of National Revenue reached the conclusion that there was no change of use of the Ennismore property and, therefore, no deemed disposition in 1976 with the result that the Ennismore property remained in inventory. ...
T Rev B decision

James C Bartlett, N M Bartlett Inc v. Minister of National Revenue, [1983] CTC 2512, 83 DTC 461

According to Mr Bartlett, the reserve claimed by the appellant was fixed after consideration, in each case, of the age of the receivable, the reason for non-payment, the means of payment available to the debtor and the debtor’s record. ...
TCC

Michajlo Bishyk v. Minister of National Revenue, [1983] CTC 2693, 83 DTC 594

In IEM the Board held that the property in question was a “government right” and that the “consideration [was] received... for allowing the expiry of a government right”. ...

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