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Results 11471 - 11480 of 14769 for considered
EC decision
Russel W. Fyke v. Minister of National Revenue, [1964] CTC 54, 64 DTC 5032
For the moment it is sufficient to say that the evidence of the appellant, corroborated by that of his wife (these were the only two witnesses called by the appellant and none were called by the respondent), establishes to my satisfaction that when considered alone there is nothing to suggest other than that the two properties were acquired solely as investments, the residence as a home for the appellant and his family and the apartment house as an investment from which he expected to and did receive rental income. ...
EC decision
Minister of National Revenue v. Roger Elkin Christie, [1964] CTC 165, 64 DTC 5099
The respondent testified that if the probationary period antecedent to active membership in the Board had not been waived, in all likelihood he would not have embarked on this venture, He also considered that active membership in the Board was essential to the suecess of his business. ...
SCC
The Deputy Attorney-General of Canada v. Eric Brown, [1964] CTC 483, [1964] DTC 5296
Circumstances may vary and the position of each client who desired to claim privilege would still require to be considered. ...
EC decision
Ben Lechter v. Minister of National Revenue, [1964] CTC 510, 64 DTC 5311
Consequently, I probably would have considered the appellant as engaged in a profitmaking scheme or venture in the nature of trade if this question were the only one raised in the instant suit. ...
EC decision
Brampton Brick Limited v. Minister of National Revenue, [1963] CTC 57, 63 DTC 1033
In the circumstances the owner might well have felt that the value of the remainder would be adversely affected by the proximity of the appellant’s brickmaking operation and while I do not doubt that before acquiring the 150 acres the directors of the appellant considered what might be done with the portion that would not be required for the extraction of clay and how it might be turned to advantage whether by using it or disposing of it, on the evidence, I can consider no good reason for thinking that there were prospects at that time of selling such portions to advantage or that prospects of selling them at a profit even constituted a motive for making the purchase. ...
EC decision
Alexander B. Davidson v. Minister of National Revenue, [1963] CTC 240, 63 DTC 1154
Interest rates were low at the time and debenture borrowing was considered to be a good way of financing the company without diluting the control of the company which Denton and the appellant had acquired. ...
EC decision
Montreal Trust Company Et Al. (Executors of Robert Newmarch Hickson, Deceased) v. Minister of National Revenue, [1963] CTC 405
In general the whole tenor of the act and the intention which it sufficiently expresses are considered, rather than the ordinary acceptation of particular words, in order t to determine whether there 1 is substitution or not. ’ ’ In a typical affair: Lussier v. ...
SCC
Her Majesty the Queen v. Joseph Machacek, [1961] CTC 1, [1961] DTC 1022
I have considered carefully the view expressed by Coady, J.A., in Jorgenson v. ...
EC decision
Anjulin Farms Limited v. Minister of National Revenue, [1961] CTC 250, 61 DTC 1182
Certain objections on the facts are also raised in the alternative, but if the legal objection now raised is correct, the others need not be considered. ...
EC decision
Earl B. Finning v. Minister of National Revenue, [1961] CTC 425, 61 DTC 1251
In a matter of simple common sense, were a ‘‘man on the street’’ asked if he considered as active a firm that did not advertise, had no telephone listing, no employee nor any office of its own, but paid another company to conduct its customary tasks, I doubt greatly whether that man would require a dictionary’s assistance to reply promptly in the negative. ...