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FCTD

Jack Appleby v. Minister of National Revenue, [1971] CTC 728, 71 DTC 5438

Appleby Securities Limited only because he happened to be the president of that company; in these circumstances, said he, since the appellant and his brokerage tirm are two distinct legal persons, the appellant cannot be considered to have personally carried on the sales campaigns unless it be found that J. ...
FCTD

Amelia Rosh v. . Minister of National Revenue, [1971] CTC 810, 71 DTC 5481

The latter two in particular considered paragraph (c) of Section 68(1). ...
FCTD

Edward M. Maber v. Minister of National Revenue, [1971] CTC 866

If possession of cattle, cultivation of the soil, or raising farm products was necessary in the period in question in order that the appellant’s activities could be considered as coming within the embrace of ‘‘farming’’, the contention would be valid, for, admittedly, the appellant did not have cattle and did not cultivate the soil or have farm produce in that period and his activities were on a much smaller scale than that which his previous operation of the whole ranch demanded. ...
BCCA decision

Minister of Finance of British Columbia v. Estate of Andrew Lawrence Carper, [1970] CTC 257

There would be no point to inquire into this question at all if it were not for subsection (6) of section 10 of our Act because in other respects our legislation is substantially the same as the provisions of the Ontario Child Welfare Act considered in Re Gage. ...
EC decision

Alberta Natural Gas Company v. Minister of National Revenue, [1969] CTC 316, 69 DTC 5230

In conclusion, the appellant did receive United States dollars for services of the appellant in transporting gas and therefore the United States dollars as measured by Canada dollars are income within the Income Tax Act and are properly considered in determining the loss to be carried forward. ...
EC decision

George W. Crothers Limited v. Minister of National Revenue, [1969] CTC 546, 69 DTC 5380

From this admission would seemingly flow the unescapable assumption that a plane devoid of those implements, the lack of which jeopardizes its normal flying security, could hardly be considered as completely “produced” or fully ‘‘manufactured”’. ...
EC decision

Dr. Barnardo’s v. Minister of National Revenue, [1968] CTC 296, 68 DTC 5200

Adopting such an approach, I am of the view that the following are relevant criteria to be considered in such a test. ...
EC decision

Harry O. Waffle v. Minister of National Revenue, [1968] CTC 572, 69 DTC 5007

However it was considered by Mr. Ledingham and the appellant that one or other of them should accept the trip because Thornerest was negotiating with Ford to extend its franchise to include the Lincoln automobile produced by Ford. ...
EC decision

Algoma Central Railway v. Minister of National Revenue, [1967] CTC 130, 67 DTC 5091

A further question must also be considered, even if that question is answered in the affirmative, as to whether a mere increase in the volume of the taxpayer’s business—no matter how large that increase may be—is an ‘‘advantage’’ of the taxpayer as contemplated by the test. ...
EC decision

Gordon $. Shipp, Harold G. Shipp, Bessie L. Shipp and June C. Shipp v. Minister of National Revenue, [1967] CTC 330, 67 DTC 5222

Shipp told Kalmar that he was not anxious to sell and would only consider a sale if the proposed purchaser purchased the shares and paid the equivalent of $1,575,000, which sum at the time he considered would be uneconomical and unacceptable to the proposed purchaser. ...

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