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TCC

Sunrise Realty Investments Limited v. The Queen, 2013 TCC 5 (Informal Procedure)

He considered the subject property value to be in the middle of this range, approximately $26 per square foot ... The most similar property is generally considered to provide the most reliable information to value. ... Information, estimates, and opinions that have been expressed in the appraisal report are obtained from sources considered to be reliable and they are believed to be true and correct. ...
TCC

9081-2769 Québec inc. v. The Queen, 2019 TCC 14 (Informal Procedure)

She did not remember the two cash transactions appearing in the Appellant’s bank account and made during the years in question, namely a $200 deposit in July 2009 and a $150 deposit in April 2010 (aside from the two deposits considered advances from the director). ... I am of the opinion that it is highly unlikely that a service company, such as a tanning and aesthetics salon, would make only two sales where payment was by cash (or cheque) over such a period (aside from the two deposits considered to be advances from the director). [31]   Ms.  ... The Queen, 2005 TCC 545, [2005] TCJ No. 396 (QL) (informal procedure), Chief Justice Bowman stated: [TRANSLATION] [11]   To distinguish between “slight” neglect or negligence and “gross” negligence, a number of factors must be considered. ...
TCC

Hébert v. The Queen, 2019 TCC 266 (Informal Procedure)

(“Hardy”), which was previously considered a bad debt and had been deducted as such in computing Mr.  ... This amount cannot be considered non-taxable lottery winnings. Similarly, it cannot be considered compensation for the losses suffered by Mr.  ... Also, the Minister probably considered that the legal fees and legal expenses paid by Mr.  ...
TCC

Kurt Pieckenhagen and Julita Pieckenhagen and Julita Investments Ltd. v. Minister of National Revenue, [1990] 1 CTC 2075, 89 DTC 725

The basis for the reassessments was that such amounts were considered to be benefits conferred on the appellants by the Corporation. ... I have considered all of these and the case law presented to the Court. ... In a more recent decision the Federal Court of Appeal considered the question in Hiwako Investments Ltd. v. ...
TCC

Lakehead Newsprint Limited v. Minister of National Revenue, [1986] 1 CTC 2442, 86 DTC 1353

The credit note should not be considered apart from the transaction out of which it arises. ... That obligation must be considered as subsisting until satisfied or expired.... ... In that event he would be satisfied that for accounting purposes a liability had been incurred by the appellant which liability could not be considered to be contingent. ...
TCC

Robert a Elliott v. Minister of National Revenue, [1984] CTC 2373, 84 DTC 1325

The respondent contends that the said amount is interest and cannot be considered as farming income. 2. ... (SN p 16) The appellant also contended that the whole amount of $60,757.74 must be considered as compensation based on paragraphs 44(2)(a) and (b) quoted above. ... In these three cases the expropriating authority calculated interest retroactively from the date of expropriation until the date of settlement and the Court considered it as income. ...
TCC

Beaudry v. R., [1998] 3 CTC 2705, 98 DTC 1898

One of the reasons the Minister considered the debt not to be bad in 1982 was that in calendar year 1983 Mirage paid dividends of $149,486. In assessing the appellant for 1983, however, the Minister considered the debt to have become bad in 1983 but was a capital loss. ... Bd.), the Tax Appeal Board considered what is bad debt, albeit with respect to the predecessor of paragraph 20(1)(/?) ...
TCC

Glenex Industries Inc. v. R., 97 D.T.C. 291, [1997] 3 C.T.C. 2217

His evidence indicated that a discounted cash flow method was generally considered to be the most appropriate means for determining the fair market value of a film library, but it was considered inappropriate under the circumstances. ... In selecting the terminal value multiples and discount rates, anticipated distribution growth opportunities available on expiration of older existing contracts, discussion with industry participants and relevant risk and return standards were considered. ... Senior was not clear and not all relevant matters were considered by Mr. ...
TCC

Wammes v. The Queen, docket 2000-1725(IT)G

He is already making payments on what he owes the Receiver General pursuant to the above judgment and he cannot pay more. [4]            Counsel for the Respondent submitted that the Bill of Costs was in accordance with Tariff A, Class A proceedings and that costs should be granted as submitted. [5]            I have reviewed and considered the submissions made by the Appellant and counsel for the Respondent and will allow costs as submitted. ...
TCC

Lind v. The Queen, docket 1999-3016(GST)I (Informal Procedure)

But I accept entirely the credibility of what has to be considered an independent witness, Mr. ...

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