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TCC

Steve Dudelzak v. Minister of National Revenue, [1987] 2 CTC 2195, 87 DTC 525

The Minister first considered the amount of $25,000 as a taxable capital gain then, in the 1984 reassessment, he considered the said amount as a shareholder benefit. ...
TCC

Kenneth Murray v. Minister of National Revenue, [1987] 2 CTC 2284, 87 DTC 559

All crew members were considered to be independent contractors or coventurers. ... Justice Walsh considered various authorities and interpreted the phrase "source of income” broadly, stating at page 859 (D.T.C. 6032): It appears to me that these definitions are broad enough to encompass either the immediate source of the income which was the payments received from the company and designated for want of some better designation as "income from employment" or the origin of this income which was from the farming operations carried out by defendants for the company. ...
TCC

John Thomas Ballard v. Minister of National Revenue, [1987] 1 CTC 2154, 87 DTC 157

Ballard has appealed the Notice of Confirmation by the Minister on the basis that the amount received by him from The Canadian Fishing Company Ltd. does not comprise remuneration from office or employment in accordance with the provisions of Subsection 6(3) of the Act and should properly be considered to be a “termination payment” as defined by the Act. ... The section 248 definition of “termination payment"' applicable with respect to amounts received in respect of terminations after November 16, 1978, and before November 12, 1981, is: “termination payment", for a taxation year, means an amount equal to the lesser of (a) the aggregate of all amounts each of which is an amount received in the year in respect of a termination of an office or employment, whether or not received pursuant to an order or judgment of a competent tribunal, other than (i) an amount required by any provision of this Act (other than subparagraph 56(1)(a)(viii)) to be included in computing the income of a taxpayer for a year, (ii) an amount in respect of which an election has been made under subsection 40(1) of the Income Tax Application Rules, 1971, and (iii) an amount received in the year as a consequence of the death of an employee, and (b) the amount by which 50% of the aggregate of all amounts each of which is the amount that may reasonably be considered to be the employee’s salary, wages and other remuneration from an office or employment for the 12 months preceding the date that is the earlier of (i) the date on which the office or employment was terminated, and (ii) the date on which an agreement, if any, in respect of the termination was entered into exceeds the amount determined under paragraph (a) for each previous year in respect of that termination whether the recipient is the officer or employee whose office or employment was terminated or a dependant, relation or legal representative of the officer or employee; It was common ground that the payment was. in respect of a termination of... employment....” ...
TCC

Omer Lortie v. Minister of National Revenue, [1986] 2 CTC 2216

Brochu extracted the arithmetic mean 4.24 and the median 4.14, and considered the GIM of the sale that most closely resembled the sale of the hotel, 4.46. ... These approaches are, however, two of the three used by appellant's appraisers, who also considered them the most important in their application of the correlation method: income approach: 38.9 per cent, cost approach: 36.1 per cent (para. 3.03). ...
TCC

Leon Broitman and Len’s Clothing and Furniture Ltd. v. Minister of National Revenue, [1986] 2 CTC 2283, 86 DTC 1711

Pillsbury Holdings Limited, [1964] C.T.C. 294 at 298-99; 64 D.T.C. 5184 at 5186-87, Catttanach, J. considered the scope of subsection 8(1) of the former Income Tax Act, predecessor of the present subsection 15(1). ... The relationship of section 8 to the rest of the statute was considered by Laskin, C.J.C. in Barbara Anne Leatherdale v. ...
TCC

David M. Rovan v. Minister of National Revenue, [1986] 2 CTC 2337, 86 DTC 1791

One subject was considered on each day. We now come to the convention which gives rise to this litigation. ... In this regard it is relevant to consider the depth of the information the taxpayer had regarding the topics to be considered when he decided to attend. ...
TCC

Stanley John McKimmon v. Minister of National Revenue, [1986] 2 CTC 2359, 86 DTC 1752

In this case Jackett, J. considered a property settlement and separation agreement made by the taxpayer and his wife which provided, among other things, that he would pay her (in full and final settlement of his obligation to support and maintain her) the sum of $20,000 of which the sum of $6,000 was payable upon execution of the agreement and the sum of $14,000 by way of equal consecutive monthly instalments of $100 each. ... Counsel contended that this aspect of the decree nisi was "probably a nullity at law” and should not be considered by this Court. ...
TCC

Edwards Fine Foods Ltd. v. Minister of National Revenue, [1986] 2 CTC 2447, 86 DTC 1815

The mixing of a number of ingredients of a drink is considered processing but the mere pouring of liquor or beer into a glass and the dispensing of draft beer are not considered processing. ...
TCC

Hackiman Lakha v. Minister of National Revenue, [1986] 1 CTC 2001

Lakha; the Minister's prime concern was that the amendment, at least, was not an authentic writing and therefore ought not to be considered by the Court. ... Also he ought to have considered the agreement, as amended. On the evidence of Sgt. ...
TCC

Malcolm Ashford v. Minister of National Revenue, [1986] 1 CTC 2044, 86 DTC 1079

(T. 17, 11. 20-25) Consequently the appellant sent letters of complaint to the president of the League asking for some type of settlement and that legal action may be considered. ... The vice-president responded that, inter alia, as long as legal action was being considered no unilateral recommendation to correct any perceived inequitable situation would be made to the Board of Governors. ...

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