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FCTD

Canadian Marconi Company v. Her Majesty the Queen, [1989] 2 CTC 128, 89 DTC 5370

Ordinarily a taxpayer must set out specifically what is considered to be wrong in the assessment for the year. ...
TCC

Pierre Boisselle v. Minister of National Revenue, [1989] 1 CTC 2385, 89 DTC 279

The Minister of National Revenue has considered the facts and reasons stated in your notice(s) of objection and hereby confirms the said assessment(s) as having been made in accordance with the provisions of the Income Tax Act, for the following reasons. ...
TCC

Daville Transport Inc. v. The Queen, 2021 TCC 47

Canada, 2007 TCJ No. 273, that the Minister should have considered on a common sense basis, “what did the supplier supply?” ...
SCC

Her Majesty the Queen v. Mark E. Grimwood, [1988] 1 CTC 44, 88 DTC 6001

.; (i) ordinarily inhabited in the year by the taxpayer, his spouse... except that, subject to section 54.1, in no case shall any such housing unit... be considered to be a taxpayer's principal residence for a year (iii) unless it has been designated by him in prescribed manner to be his principal residence for that year and no other property has been so designated by him for that year, or (iv) by virtue of subparagraph (ii), if by virtue of that subparagraph the property would, but for this subparagraph, have been his principal residence for four or more previous taxation years, and for the purposes of this paragraph the “principal residence” of a taxpayer for a taxation year shall be deemed to include... the land subjacent to the housing unit and such portion of any immediately contiguous land as may reasonably be regarded as contributing to the taxpayer's use and enjoyment of the housing unit as a residence, except where... ...
TCC

Mary Jane Stephens and the Estate of William R. Stephens v. Minister of National Revenue, [1988] 1 CTC 2249, 88 DTC 1170

On the other hand some of her other evidence must be considered. After her husband's death, investment difficulties and other differences arose between her and her son. ...
TCC

Eleanor B. Kushnir, Audrey N. Maclean, Peter L. Hartman, Ben Bauer v. Minister of National Revenue, [1986] 1 CTC 2514, 86 DTC 1381

He said that it was his practise in dealing with parents of children he examined to mask the true nature of the problem identified because of what he considered potential harm. ...
TCC

The Estate of the Late John N Gladden v. Minister of National Revenue, [1984] CTC 2243, 84 DTC 1242

. — No Canadian cases have yet considered the deemed disposition provisions of subsection 70(5). ...
T Rev B decision

Ronald B Phillips v. Minister of National Revenue, [1983] CTC 2281, 83 DTC 267

However, there remained a balance of only $2,500 ($32,500- $30,000), and the preponderance of the evidence is to the effect that the amount of $12,393.32 ($14,893.32- $2,500) must be considered as income. 4.02.3 Third Point: $5,000 (1975) Because there are no vouchers, and because these expenses were “not claimed previously by management estimated only”, pursuant to a note in the accounting books, the Board is not inclined to accept them. ...
T Rev B decision

Richard Binette v. Minister of National Revenue, [1983] CTC 2447, 83 DTC 416

The Board is of the opinion that whatever the administrative procedure used in making the payments, source deductions and remittances, it is the substance of the agreement which must be considered to determine the real salary paid and the deductions and remittances actually made. ...
T Rev B decision

Cogem Inc, Publicité Cogem Ltée v. Minister of National Revenue, [1982] CTC 2575, 82 DTC 1596

Conclusion of the Supreme Court I cannot agree that the particular facts of this case, when considered in the light of the Crown’s concession of the good faith of the respondent in incorporating a company to operate a private hospital and the eschewing by the Crown of any suggestion of sham, provide a basis upon which to uphold the assessments against the respondent. ...

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