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SCC

Judgment Accordingly. Montreal Trust Company, Trustee of the Estate or Lodestar Drilling Company Limited, a Bankrupt v. Minister of National Revenue, [1962] CTC 417

Ford apparently controlled the operations of the company and as the anticipated cost of drilling the well on the farmout in question was about $55,000 he considered this was too big an investment for the company and, accordingly, sold the half interest to the Reality Company for the sum of $27,500. ...
T Rev B decision

Donald Engene Morgan, Maitland Almost, Carlyle a Bodkin and Frank E Cassin v. Minister of National Revenue, [1973] CTC 2192, [1973] DTC 146

I have considered the interest that they have in the outcome of this appeal, and I have no hesitation whatsoever in finding, in all four cases, that they are credible witnesses, and I accept their evidence, as given today, without qualification. ...
T Rev B decision

Louis Bratanek, Jr v. Minister of National Revenue, [1978] CTC 2379, [1978] DTC 1275

I would have grave difficulty concluding that the appellant at no time considered the rental income producing potential from his acquisitions and related only to their potential resale prospects. ...
T Rev B decision

DR J G Cyr v. Minister of National Revenue, [1978] CTC 2757

The appellant considered this to be a good price as the airplane would cost $300,000 new, and the radio system alone was worth $100,000. ...
T Rev B decision

George Marinis v. Minister of National Revenue, [1978] CTC 2821, [1978] DTC 1609

From this viewpoint, the Board is of the opinion that, in the case at bar, the respondent cannot be considered to be a creditor of the partnership. ...
T Rev B decision

Guy Dumas v. Minister of National Revenue, [1978] CTC 2961, [1978] DTC 1704

To demonstrate that the project was seriously considered, Mr Dumas submitted stationery with the letterhead ‘Place Henri IV’’ and a list of expenses (Exhibit A-17): EXPENSES 1—Robert Morin (accountant) $ 4.000.00 2—Begin, Charland, Valiquette (appraisers) $ 3.235.58 3—Duval, Grenier, Taschereau (notary) $ 2,580.00 4—School and municipal taxes $ 27,130.32 5—St-Gelais, Tremblay, Tremblay and L'Abbé (architect) $ 12,495.16 6—Cossette and Associates $ 145.42 7—André Blanchet (lawyer) $ 43,000.00 8—Thron, Group and Co (accountant) $ 4,435.36 9—Travel expenses, accommodation and meals $ 3,133.06 10—Lease with Wilfred Légaré Inc $ 665.00 TOTAL $100.819.90 On September 22, 1969 Mr Dumas received a letter from Mr Gauv- reau telling him that Eaton’s was not interested in locating in Quebec City; he further learned that Simpsons-Sears was moving into the Laurier Project. ...
T Rev B decision

Gordon a Bryce v. Minister of National Revenue, [1978] CTC 3144, [1978] DTC 1833

His next approach was, in effect, that section 60.1 should be considered remedial and given a liberal interpretation and, in the result, broadening the decision of Mr Justice Pratte in the Pascoe case—something more than that which is an allowance within his definition is now allowed by the addition to the Act of section 60.1. ...
T Rev B decision

Hady Construction (1971) LTD v. Minister of National Revenue, [1980] CTC 2135, [1980] DTC 1101

Nor does the regulation say that, if the operation of the business produces a net loss for the year, that operation cannot be considered the appellant’s principal business. ...
T Rev B decision

George G Addie v. Minister of National Revenue, [1980] CTC 2647, [1980] DTC 1556

He had to keep up with modern techniques and technical developments in chemistry and indicated that in the Public Service, so-called professional societies are considered desirable qualifications. ...
T Rev B decision

Edward C Sargent v. Minister of National Revenue, [1983] CTC 2639

It is laid down thus in City Discount Co v McLean by Blackburn J (LR 9 CP 700), and expressed by Lord Selborne in Re Sherry (25 Ch D 702), in somewhat similar language: “It has been considered a general rule since Clayton’s case that when a debtor makes a payment he may appropriate it to any debt he pleases and the creditor must apply it accordingly. ...

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