Search - consideration

From a consideration of all the facts which have been disclosed in the evidence adduced at the hearing, I have reached the conclusion that the liability assumed in connection with Vaillancourt Inc’s line of credit, and which the appellant was called upon to pay, was nothing other than an outlay of capital made by it on behalf of P P Vaillancourt Inc, no doubt with the hope of preserving what had in the past proved to be, for the appellant, a valuable source of lumber at an advantageous price. ...

From the material before the Board, it is clear that, in respect of the assessments for the 1963 to 1966 taxation years, an interval of 99 days had elapsed between the date of mailing of the Minister’s notifications under section 58 and the date of mailing of the purported notices of appeal to the Tax Appeal Board, and that the purported notices of appeal presented to the Board for consideration had been mailed to, and received by, the Registrar of the Tax Appeal Board well beyond the 90-day period reserved by statute for instituting an appeal. ...

The appellant purchased the aforesaid lots by deed dated December 2, 1963 for a total consideration of $4,500 from the executors of the estate of the late John M Irwin. ...

In 1967 he accepted an offer for approximately 4 acres of land realizing a gain of $72,830.93, After careful consideration, it is not necessary in my opinion to review all the assumptions and all the factual details established in evidence. ...

Acreage considerations were disregarded in this division, as the appellant wanted the more picturesque Pottruff farm which had a creek and ravine running through it, and on which was located an old stone house in an attractive wooded setting. ...

During the years under consideration the appellant company paid on behalf of the said purchasers, the principal and interest which fell due on the aforesaid mortgage and the bank interest on the bank loan as it accrued. ...

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. ...

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. ...

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? ...

Argument Cases presented to the Board for consideration, and to which reference was made by both parties, were as follows: Christopher John Goodman v MNR, 8 Tax ABC 320; 53 DTC 225; Herman Luks (No 2) v MNR, [1958] CTC 345; 58 DTC 1194; William Robert Martyn v MNR, 35 Tax ABC 428; 64 DTC 461; Norman Lusby Goodwin v MNR, [1971] Tax ABC 42; 71 DTC 67; William H. ...