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TCC

John Dick and Beverly Dick and Dick's Garage Limited v. Minister of National Revenue, [1991] 2 CTC 2034, 91 DTC 811

In this way, the appellants did place their cause at considerable risk, a factor which I considered seriously in the review. ...
TCC

Norman C. Soldera v. Minister of National Revenue, [1991] 2 CTC 2097, 91 DTC 987

The soundness of the position I have adopted respecting the the nature and character of the $7,500 payment by the appellant becomes, I believe, more apparent if the hypothetical situation that follows is considered. ...
TCC

Richard Struble v. Minister of National Revenue, [1991] 2 CTC 2207

Each case must be considered on the merits of its own facts and circumstances. 4.03.05 The facts in the present case do not indicate that the taxpayer experienced a change of mode or habit of work or a significant change in his farming operation since he started in 1979. ...
TCC

Peppino Bassani v. Minister of National Revenue, [1991] 2 CTC 2388, 91 DTC 1084

As a matter of interest, she also considered certain other sales of property for their content of granular material (a better quality of sand and gravel than in the subject property) and concluded that values of property for sand and gravel content were lower per acre than values for country residential purposes. ...
TCC

Estate of Jeffrey O'BRIEN by Its Executors the Canada Trust Company of Peter O'BRIEN v. Minister of National Revenue, [1991] 2 CTC 2747

This rule, considered one of the canons of trusteeship, requires that the trustee must not show favouritism toward one beneficiary against another and necessitates careful and constant attention to see that the trustee is neither seeking a higher annual return at the risk of capital, or unduly safeguarding principal to the detriment of income: (page 5) Mr. ...
TCC

Kodandaram Balasubramian v. Minister of National Revenue, [1991] 2 CTC 2812

Each appeal from an assessment under section 227.1 is to be considered on its own particular set of facts. ...
TCC

Aaron Shtabsky v. Minister of National Revenue, [1990] 2 CTC 2113, 90 DTC 1621

., or (b) property taxes... if... the land cannot reasonably be considered to have been in that year, (c) used in, or held in the course of, carrying on a business by the taxpayer other than a business in the ordinary course of which land is held primarily for the purpose of resale or development... except to the extent that the taxpayers gross revenue, if any, from the land for that year exceeds the aggregate of all other amounts deducted in computing his income from the land for that year. ...
TCC

Estate of Roger Gilbert and Therese Gilbert v. Minister of National Revenue, [1990] 2 CTC 2185, 90 DTC 1660

It must also be considered that, by virtue of subsection 153(3) the employees are deemed to have received their wages in full, so that they are liable for income tax on that basis. ...
TCC

Gaston Bergeron and Diane Bergeron and Aurore Bergeron v. Minister of National Revenue, [1990] 2 CTC 2220, 90 DTC 1511

The appellant considered various possibilities and was inclined toward the creation of a small business making and selling kitchen cupboards and renovating houses. ...
TCC

Hypark Investments Ltd. v. Minister of National Revenue, [1990] 2 CTC 2254, 90 DTC 1752

Berkowitz was disappointed in this sale, briefly considered buying the other interests in the project herself then discarded the idea. ...

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