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TCC

Edith D’argys v. Minister of National Revenue, [1992] 2 CTC 2778

In fact, she states in her testimony that she considered Mr. Pouliot as" her bank” [translation] (S.N., page 90). 3.07 According to the appellant, Mr. ...
FCA

Her Majesty the Queen v. Sie-Mac Pipeline Contractors Ltd., [1992] 1 CTC 341

Justice Muldoon's reasons that he considered the respondent's motion a request for a substantive determination (as to whether or not the applicants’ motion pursuant to subsection 232(4) was moot) and not merely an order for directions. ...
TCC

Alberto Bentivogli v. Minister of National Revenue, [1992] 1 CTC 2251, 92 DTC 1136

That the moneys were kept in a safety deposit box not paying interest was not considered important since, according to Mr. ...
TCC

R. Rousseau & Fils Ltée v. Minister of National Revenue, [1992] 1 CTC 2426

Gaz & Oil Ltd. (4.02.3). 4.03.7 The appellant further argued that the “fixed assets" test must be considered. ...
TCC

John Meeuse v. Minister of National Revenue, [1992] 1 CTC 2470, 92 DTC 1549

One of the options considered was the buying of houses and fixing them up with a view to profitable resale. ...
TCC

Richard Courville and Bernard Jacques v. Minister of National Revenue, [1992] 1 CTC 2546, 92 DTC 1888

He was considered to have a high level of expertise and solid experience in the field of visual effects. ...
TCC

Michel Seguin and Barbara Seguin v. Minister of National Revenue, [1992] 1 CTC 2711, 92 DTC 1502

This comment is provided in relation to the fact that $42,178 of expenditures were considered eligible for such research categorization (see reply to notice of appeal above) and that is the basis upon which the assessments were calculated. ...
FCTD

Her Majesty the Queen v. National Bank of Canada, [1991] 2 CTC 183

Thus, the letter is far from being as clear and formal as that considered in the following passage from the judgment in Valence v. ...
FCTD

Crestbrook Forest Industries Ltd. v. Her Majesty the Queen, [1991] 2 CTC 195, 91 DTC 5521

This determination will vary with the circumstances of each case, but here, having examined the full text of the report, I considered it appropriate to accept counsel's undertaking of nondisclosure, even to his client, and to allow him access to the disputed portion solely for the purpose of argument. ...
FCA

Danford Evan Eugene Bodrug and National Trust Company, Executors of the Estate of Evan Wesley Bodrug, Deceased v. Her Majesty the Queen in Right of Canada, [1991] 2 CTC 347

At pages 9-11 of his reasons for judgment he stated: The question therefore is simply this: can the damages awards in question properly be considered part of the “cost to the taxpayer" of the Hidrogas shares? ...

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