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TCC

Gladys Balsillie v. Minister of National Revenue, [1985] 2 CTC 2367, 85 DTC 652

Counsel for the appellant argued that a pattern of cheque cashing had been established but that such pattern had never been analysed or considered by the respondent. ...
TCC

The Estate of John S McEachran, Deceased v. Minister of National Revenue, [1985] 2 CTC 2474, 86 DTC 1001

The law firm considered this mortgage to be doubtful in 1979 and in anticipation of making good on any loss to its client, it claimed a $5,000 reserve or allowance in determining its income for its fiscal year ending September 30, 1979. ...
TCC

Joseph Gleddie v. Minister of National Revenue, [1985] 1 CTC 2217, 85 DTC 224

The appeals are allowed in part in order that for the years 1977, 1978 and 1979, Mr Gleddie shall be considered an independent contractor. ...
TCC

Les Ateliers Benoît Allard Inc v. Minister of National Revenue, [1984] CTC 2189, 84 DTC 1131

As a general rule, the on-site fabrication, installation and erection of machinery and equipment, regardless of size, is not considered to be construction, unless it constitutes a component part of a building or structure (eg — heating system, air- conditioning equipment, sprinkler system, plumbing, wiring, etc.). ...
TCC

Charles H Roney v. Minister of National Revenue, [1984] CTC 2701, 84 DTC 1431

It would be normal that all the losses of one year be considered as start-up costs even if in that year the appellant was not yet a full-time farmer but a gentleman farmer. ...
TCC

Susan Bracken v. Minister of National Revenue, [1984] CTC 2922, 84 DTC 1813

Subsection 37(2) of the Interpretation Act provides: 37. (2) The amendment of an enactment shall not be deemed to be or to involve a declaration that the law under such enactment was or was considered by Parliament or other body or person by whom the enactment was enacted to have been different from the law as it is under the enactment as amended. ...
TCC

Odette (Estate) v. The Queen, 2021 TCC 65

The presumption of consistent expression therefore favours an interpretation according to which, if Parliament intended for “consideration received or receivable” to be considered for deeming the fair market value of the property gifted, Parliament would have chosen the appropriate words, as it has in so many other instances. [44] The evidence also shows that on December 23, 2013, the only thing “received” by the Foundation was the Promissory Note. ...
TCC

O’connor v. R., [1997] 2 CTC 2075

It was Court who considered the payments as a rent and adjusted the relevant accounts when preparing the statement for 1990. ...
TCC

Chevron Canada Resources Ltd. v. R., [1997] 2 CTC 2624, 97 DTC 1173

This matter was considered by Judge Garon in Cie Price Ltée c. R., (1993), 95 D.T.C. 428 (T.C.C.). ...
TCC

Canadian Solifuels Inc. v. R., [1998] 1 CTC 3080, 98 DTC 1311

This represented 7.5% of the total funds raised of $2.2 million and the Minister considered that 7.5% was a reasonable financing cost. ...

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