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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. ...
FCA

Roywood Investments Ltd. v. The Queen, 81 DTC 5148, [1981] CTC 206 (FCA)

It cannot be said he overlooked any material evidence or took into consideration factors for which there was no evidence. ...
FCA

Perkins v. The Queen, 80 DTC 6154, [1980] CTC 199 (FCA)

In our view, all of the relevant findings of fact made by the learned trial judge were open to him on the evidence adduced; the conclusions and inferences which he drew from the proven facts were not erroneous and were drawn by him only after an extensive consideration and review of the evidence. ...
TCC

Edmondson v. MNR, 88 DTC 1542, [1988] 2 CTC 2185 (TCC)

As a consideration for doing this the appellant insisted on co-signing all cheques and having his daughter, an experienced bookkeeper, work for the Company. ...
SCC

Robson v. Minister of National Revenue, 52 DTC 1088, [1952] CTC 85, [1952] 2 SCR 223

The same construction results from a consideration of the French version of the text:— 1 ‘ et doit comprendre l’intérêt, les dividendes ou profits directement ou indirectement reçus de fonds placés à intérêt sur toutes valeurs ou sans garantie, ou d’actions, ou de tout autre placement, et, que ces gains ou profits soient partagés ou distri- bués ou non, et aussi les profits ou gains annuels dérivés de toute autre source, y compris. ’ ’ The distribution of the shares by Timberland was not a distribution of capital of that company. ...
FCTD

Finochio v. The Queen, 87 DTC 5228, [1987] 1 CTC 313 (FCTD)

Ross indicated they were concerned and contacted their insurers) and income tax considerations, all of which would benefit from seeing the letter. ...

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