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T Rev B decision

Muriel Anne McGuire v. Minister of National Revenue, [1982] CTC 2830, 82 DTC 1813

Supreme Court of Canada decision Jack Cewe Ltd v Jorgenson, [1980] CTC 314; 80 DTC 6233, in which the Supreme Court gave serious consideration to whether or not, in that matter, the damages at issue flowed out of the contract of employment. ...
T Rev B decision

Sivaco Wire & Nail Company, Industrial Fasteners LTD v. Minister of National Revenue, [1981] CTC 2081, 81 DTC 140

Counsel for the Minister suggested that consideration should be given to the totality of the materials used in the building, including the inner core of steel in the structure itself, and to the fact that the outside covering was made of steel, not iron—as iron is understood in the natural state. ...
T Rev B decision

Martin a Bitz v. Minister of National Revenue, [1981] CTC 2426, 81 DTC 382

In 1969, the taxpayer and three other persons acquired a parcel of farm land (approximately 48 acres) on the easterly limits of the City of London, for a consideration of $75,000, the respective interests being in the proportion of 6, 6, 4 and 4. ...
T Rev B decision

Arcade Construction LTD v. Minister of National Revenue, [1981] CTC 2845, 81 DTC 655

The obligation might have been extinguished by an agreement in the nature of an accord and satisfaction if supported by consideration. ...
FCTD

Irvine Henry Graham v. Her Majesty the Queen, [1980] CTC 212, 80 DTC 6141

On full consideration of a'l factors in respect to the claimed expenses, I cannot find and hold that there is complete and full acceptable proof of reasonable and proper expenses in repairs, etc, of the plaintiff’s rental properties totalling the amounts disallowed on the reassessments for the years 1970, 1971 and 1972. ...
T Rev B decision

C W Moncrieff v. Minister of National Revenue, [1980] CTC 2039, 80 DTC 1035

We therefore request that the above circumstances be taken into consideration in Mr Moncrieff’s appeal and that of the annuity payments reported on the T4RSP issued by NALACO, an amount proportional to the pension plan proceeds/total annuity premium be considered eligible for the pension plan deduction in 1977 and future years. ...
T Rev B decision

Howden Brothers Construction LTD v. Minister of National Revenue, [1980] CTC 2103, 80 DTC 1098

Counsel for respondent terminated his argument by saying that Class 10 takes into consideration the duration of an asset and, because they are aluminum forms, they have a much longer life expectancy than the wooden forms, and they fall under Class 10(h) instead of Class 12(d). ...
T Rev B decision

Richard Zingel v. Minister of National Revenue, [1980] CTC 2466, 80 DTC 1424

Evidence and Argument Although little was added at the hearing to the already available information, it was clear to the Board that the appellant understood the limitation provision but at the same time, he put forward for serious consideration the plight of many employees working under similar “temporary” conditions or under circumstances wherein they might work for several different employers in a relatively short period of time. ...
T Rev B decision

Alec Eisen v. Minister of National Revenue, [1980] CTC 2527

It was argued that in determining the nature of Mr Eisen’s business activities it is insufficient to look at the income which he received personally, but rather that consideration must be given to the variety of ventures undertaken for the account of Albill. ...
T Rev B decision

J Wayne Bryant v. Minister of National Revenue, [1980] CTC 2529, 80 DTC 1428

The facts according to the appellant 4.01 During the taxation year 1975, the appellant was employed by Hoffman-La Roche Limited as a medical representative. 4.02 After addressing an application for employment dated July 8,1974 (Exhibit A-9), the appellant received a letter dated July 25, 1974 (Exhibit A-8) confirming his employment with Hoffman-La Roche commencing August 1, 1974. 4.03 This confirmation, however, was subject to certain conditions: Please note that final consideration for employment and continuing employment with Roche will be conditional upon: 1. ...

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