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T Rev B decision

Hendrik Koetsier v. Minister of National Revenue, [1974] CTC 2011

It now appears that all private schools receive the same consideration. ...
T Rev B decision

Margaret Ann Frappier v. Minister of National Revenue, [1974] CTC 2167, 74 DTC 1128

In analysing the nature of the payment of $49,029.03 made by the appellant to her clients, I find not only that there was no legal obligation on the part of the appellant to pay the amount to her clients, but there was no consideration whatsoever on the part of the clients for moneys so paid to them and no commitment that they would continue to invest through the appellant’s services (Exhibit A-3). ...
T Rev B decision

Ken & Ray’s Collins Bay Supermarket Limited v. Minister of National Revenue, [1974] CTC 2267

Considering the evidence of Mr McEwen, which I accept, I think that there is certainly, in the manner in which he and his co-shareholder operated the business, justification for the granting of these bonuses in consideration of the work they were doing. ...
QCSC decision

Robert Howard Smith, G Meredith Smith and Gardner Howard Smith, Executors of the Last Will and Testament of Edmund Howard Smith, Robert Howard Smith, Jr, Kathleen Patricia Smith, Gordon Edmund Howard Smith, Andrea Louise Smith (Wife of Lan David Ritchie), Philip Howard Smith and Dorothy Laura Smith (Wife of Henry Cole) v. Deputy Minister of Revenue of the Province of Quebec, [1973] CTC 136

In consideration of said sale, the newly formed company, Clarke Place Investments Inc, issued to the deceased 25,000 5% non-cumula- tive redeemable preferred shares of the par value of $100 each and 1,000 being all of the authorized common shares of the par value of $1 each, in its capital stock. ...
FCA

Minister of National Revenue, Appellant,, [1973] CTC 345, 73 DTC 5281

What is contemplated is a profit-making process consisting of such physical acts and the disposition of the products for a consideration by sale or other wise. ...
T Rev B decision

Maurice Alexander Clegg v. Minister of National Revenue, [1973] CTC 2014, 73 DTC 10

The problem here is this: Should the premium that an individual pays in exercising his option to obtain the extra coverage granted by the group-policy makers—in this case Mutual Life—be taken into consideration in calculating the benefit to him envisaged by the Act? ...
T Rev B decision

Charles a Specht v. Minister of National Revenue, [1973] CTC 2018, 73 DTC 25

In consideration of receiving $200,000 payable within a period of five years the appellant agreed to three undertakings by him as therein set forth. ...
T Rev B decision

Antoine Hullmann and Gabrielle Hullmann v. Minister of National Revenue, [1973] CTC 2106

From the evidence adduced in these appeals, I conclude that Antoine and Gabrielle Hullmann acquired the properties which are the subject matter under consideration for the purpose of resale and not for a long-term investment, that their conduct in these transactions was that of an adventure in the nature of trade, and that the profits realized from the sales of these properties were properly included in the income of Antoine and Gabrielle Hullmann for the 1964, 1966, 1967, 1968 and 1969 taxation years. ...
T Rev B decision

Allison Janet Craig v. Minister of National Revenue, [1973] CTC 2119, 73 DTC 116

The existence of the first mortgage of $16,000 on the property was not taken into consideration and though the evaluation was $29,000, the assessment on the property was $21,762. ...
T Rev B decision

Jacob Byke, Mitchell Byke and Stella Byke v. Minister of National Revenue, [1972] CTC 2332, 72 DTC 1299

Upon a consideration of the évidence as a whole, I am satisfied that Mary Byke had no funds of her own with which to invest in the purchase of shares of the Tecumseh Hotel and, therefore, the shares transferred to and registered in her name were in fact beneficially owned by her husband Jacob Byke. ...

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