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TCC

Jim a McClurg v. Minister of National Revenue, [1984] CTC 2469

The consideration was made up of payments of: $75,000 by the appellant and by Mr Ellis; a $37,500 demand note signed by Ellis and the appellant, and their wives, and this was secured by a term certificate of the appellant’s father-in-law. ...
TCC

Frederick H Herbert v. Minister of National Revenue, [1984] CTC 2778, 84 DTC 1703

. — Upon the recommendation of Mr Paterson and before May 26, 1976, the Appellant purchased the videotape in the series identified as Episode 29, for a consideration of $40,000. ...
TCC

William T Betz v. Minister of National Revenue, [1984] CTC 2889, 84 DTC 1766

The relevant section of the Income Tax Act, SC 1970-71-72, c 63, to which I must give consideration is paragraph 8(1)(h) which reads as follows: 8. (1) In computing a taxpayer’s income for a taxation year from an office or employment, there may be deducted such of the following amounts as are wholly appli- cable to that source or such part of the following amounts as may reasonably be regarded as applicable thereto: (h) where the taxpayer in the year, (i) was ordinarily required to carry on the duties of his employment away from his employer’s place of busines or in different places, (ii) under the contract of employment was required to pay the travelling expenses incurred by him in the performance of the duties of his office or employment, and (iii) was not in receipt of an allowance for travelling expenses that was by virtue of subparagraph 6(l)(b)(v), (vi) or (vii), not included in computing his income and did not claim any deduction for the year under paragraph (e), (f) or (g), amounts expensed by him in the year for travelling in the course of his employment; The appellant relied quite strongly on the case of The Queen v Mervin J Patterson, [1982] CTC 371; 82 DTC 6326, a decision of Cattanach, J of the Federal Court — Trial Division. ...
T Rev B decision

Joseph C Williams v. Minister of National Revenue, [1983] CTC 2207, 83 DTC 186

A municipal committee later reached the conclusion that servicing and traffic considerations dictated that a larger parcel which included the five acres had to be “done by one developer on an overall basis”. ...
TCC

Lawrence Shapiro v. Minister of National Revenue, [1983] CTC 2618, 83 DTC 563

The parties then agreed that another member of the Board give judgment on the basis of consideration of the record and transcript of the evidence and argument. ...
T Rev B decision

Leon Roy v. Minister of National Revenue, [1983] CTC 2644, 83 DTC 576

Certainly, Mr Roy’s stays or series of stays in Ireland may have lasted longer than he had originally planned; the stays may have indeed been more enjoyable than he might have expected; and he might have liked to stay on for the higher pay and given that prospect serious consideration. ...
T Rev B decision

Melvin Pisony v. Minister of National Revenue, [1982] CTC 2010, 82 DTC 1023

His Lordship said at 327 [5219]: I agree that these documents which were prepared contemporaneously and relate to the same transaction should be read together; but, so reading them, it appears that the agreement between the parties was not that the husband should pay his wife a periodic allowance for maintenance and that his agreement to do so should be collaterally secured by a second mortgage; it was rather a release by her of all her claims for an allowance and the giving by her (in paragraph 4 of the agreement) of an irrevocable power of attorney to bar her dower in her husband’s lands in exchange for a single consideration, the giving of the mortgage for $45,000.00. ...
T Rev B decision

Magilb Development Corp LTD v. Minister of National Revenue, [1982] CTC 2278, 82 DTC 1249

The events in question involved consideration of a scheme for the erection of a senior citizen’s home on part of the property, the extraction of sand from the property and an application for permission to develop a mobile home park on the property. ...
T Rev B decision

Nan M Goodwin v. Minister of National Revenue, [1982] CTC 2675, 82 DTC 1679

None of these questions were explored in de- tail at the hearing; they appear to the Board to have been considerations that any willing buyer and willing seller might have taken into account in 1971. ...
T Rev B decision

Irving a Taylor v. Minister of National Revenue, [1982] CTC 2845, 82 DTC 1829

Counsel for the appellant, in support of his statement cited the words of LaCourciére, J of the Ontario Supreme Court, RFL Vol 4, at 160 in the case of Davis v Davis: With the utmost respect for the order made by the learned Senior Master, it is my conclusion on the authorities that once a de facto marriage has been acknowledged and established, alimony will be awarded pendente lite; the determination of the parties’ rights de jure is not a relevant consideration on the application for interim alimony. ...

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