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TCC

Fitzpatrick v. The Queen, docket 98-271-IT-I (Informal Procedure)

The following criteria should be considered: the profit and loss experience in past years, the taxpayer's training, the taxpayer's intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...
TCC

Thomas v. The Queen, docket 98-87-IT-G

He simply had to rent his residence because he could not sell it at a price he considered reasonable. ...
TCC

Girard v. The Queen, docket 98-2287-IT-I (Informal Procedure)

The following criteria should be considered: the profit and loss experience in past years, the taxpayer's training, the taxpayer's intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...
TCC

Nussey Estate v. The Queen, docket 97-1569-IT-G

I have decided that the results of the two appeals, considered together, are mixed, one favouring the Minister and one favouring the estate, and further that the issue in these appeals was novel. ...
TCC

Lavergne v. M.N.R., docket 98-379-UI

Lavergne clearly stated that the company served at most six or seven customers, thus contradicting the appellant's testimony on a fairly important point, particularly for a person who claims that she was responsible for all the clerical work made necessary by the company's operations. [19] On the matter of the assessment of the time required for the publicity and promotional work, the Court finds no fault with the way in which the respondent considered or assessed this aspect of the appellant's work. ...
TCC

Burkart v. The Queen, docket 95-1363-IT-G

Burkart, may amend his pleadings and then the matter of the appeal itself must be considered. ...
TCC

Immeubles Jean Lacaille Inc. v. The Queen, docket 1999-2841(EI)

Without the drivers' participation, the appellant could not offer the home delivery service since the workers were an integral part of the operations of the appellant's business. [19]     It is the whole of the various elements that must be considered in concluding that there was an employer-employee relationship between the appellant and the workers. [20]     The appeal is dismissed. ...
TCC

Wood v. The Queen, docket 2000-1272-IT-I (Informal Procedure)

It had what they considered to be the right nozzles to assist her. With its use, she has become more mobile both within and outside of her dwelling. [12]          Paragraph 118.2(2)(m) of the Income Tax Act reads: 118.2 (2) For the purposes of subsection (1), a medical expense of an individual is an amount paid... ...
TCC

510492 B. C. Ltd. v. The Queen, docket 1999-3677-IT-G

At page 2 of that decision, Prowse J. stated:                 Given that as long as a company is struck from the Register of Companies it cannot commence an action... or maintain one,... the action is considered to be an abuse of process... and continued at page 3:... ...
TCC

Disbrowe v. The Queen, docket 98-2448-IT-G

Moreover the parties were attempting to switch from one tax structure which ensured the companies involved were not associated with the tax advantages described above to another in an attempt to secure further tax advantages on a different basis. [9] Also, I do not believe the previous treatment, on certain occasions, of capital gains, dividends and interest as being solely those of the Appellant on his returns, is all that significant given the testimony that the Appellant and Cindy considered everything to be fifty-fifty plus the factors of the joint bank account, no separate accounts and the guarantees secured by joint mortgages on their home. [10] In Holizki v. ...

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