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TCC

Luxury Home Landscape Construction Inc. v. The Queen, 2021 TCC 4 (Informal Procedure)

Regardless I cannot find that CRA’s “ special mail services request form ”, albeit presumably with a Canada Post “ tracking number ” stamped or affixed thereon, can reasonably be considered, “ the post office certificate of registration of the letter or a true copy of the relevant portion thereof ” per subsection 335(1). ...
TCC

Sheldon Benjamin v. Minister of National Revenue, [1991] 1 CTC 2041, 91 DTC 175

After reviewing the appellant's 1982 income tax return, the Edmonton office of RCT sent a letter to the appellant dated March 27, 1984 stating that a penalty under subsection 163(1) of the Income Tax Act was being considered and inviting the appellant to provide any information or explanation which might establish that the penalty was not applicable. ...
TCC

Jean-Paul Rouleau Estate v. Minister of National Revenue, [1991] 1 CTC 2055, 91 DTC 115

If the clientele or goodwill is considered property within the context of paragraph 12(1)(g), it may then be said that the amounts received by Mr. ...
TCC

Frank Foldy v. Minister of National Revenue and Linda Jarian v. Minister of National Revenue, [1991] 1 CTC 2175, 91 DTC 361

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

Jacob Wipf and Elizabeth Wipf v. Minister of National Revenue, [1991] 1 CTC 2195, 91 DTC 302

No competing source existed.Counsel referred to dictionary definitions of the word "source" and to decisions in which the meaning of the term “source of income" was considered. ...
TCC

Deborah Mastronardi v. Minister of National Revenue, [1991] 1 CTC 2302, 91 DTC 341

Morden, J. implied that the fact that the solicitor in that case was not called may be considered in weighing the evidence. ...
TCC

Wilfred L. Giffin and Fundy Construction Company Limited v. Minister of National Revenue, [1991] 1 CTC 2306, 91 DTC 421

He considered these all to be business purposes-related. He sets out in argument, and gave evidence in support of, the periods of time that he occupied the property personally. ...
TCC

Satellite Earth Station Technology Inc. v. Minister of National Revenue, [1991] 1 CTC 2416, 91 DTC 337

We tried a sandbox... we were trying all sorts of different things to get new designs, so it was never even considered that we would need to have blueprints for the things that we were working on... ...
TCC

Gustav A. Panz v. Minister of National Revenue, [1991] 1 CTC 2459, 91 DTC 125

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

Ronald Funnell v. Minister of National Revenue, [1991] 1 CTC 2498, 91 DTC 787

Both the interest-free amounts and certain items of travel were not considered proper by Revenue Canada, and such are set out above. ...

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