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TCC
Blandine Girard L’hérault and Alain L’hérault v. Minister of National Revenue, [1993] 2 CTC 2612, 93 DTC 1108
[Alternate plea] With reference to the alternative plea in the statement of defence, if it may be considered as an allegation of an "assumption"... ...
TCC
Ibm Canada Ltd. v. Minister of National Revenue, [1993] 2 CTC 2860
This argument was considered in French Shoes and in Woodward. In French Shoes, Teitelbaum, J. relied on the Interpretation Act, R.S.C. 1970, c. 1-23, to find that the new paragraph 12(1)(x) did not change the law. ...
TCC
Henry Sliwinski v. Minister of National Revenue, [1993] 1 CTC 2729
At this time the Penturns considered that Henry was indispensable to the operation and sale of London Loan Ltd. ...
TCC
Floyd R. Glass Jr. v. Minister of National Revenue, [1992] 2 CTC 2133
For the years 1980 to 1982, subsection 18(2) of the Act provided as follows: 18 (2) Notwithstanding paragraph 20(1)(c), in computing the taxpayer's income for a taxation year from a business or property, no deduction shall be made in respect of any amount paid or payable by the taxpayer in the year and after 1971 as, on account, or in lieu of payment of, or in satisfaction of, (a) interest on borrowed money used to acquire land, or on an amount payable by him for land, or (b) property taxes.... if, having regard to all the circumstances, including the cost to the taxpayer of the land in relation to his gross revenue, if any, therefrom for that or any previous year, the land cannot reasonably be considered to have been, in that year, (c) used in, or held in the course of, a business carried on in the year by the taxpayer, or (d) [Repealed] (e) held primarily for the purpose of gaining or producing income of the taxpayer from the land for the year. except to the extent.... ...
TCC
Digby R. Kier v. Minister of National Revenue, [1990] 1 CTC 2055, 89 DTC 710
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
Pierre Boisselle v. Minister of National Revenue, [1989] 1 CTC 2385, 89 DTC 279
The Minister of National Revenue has considered the facts and reasons stated in your notice(s) of objection and hereby confirms the said assessment(s) as having been made in accordance with the provisions of the Income Tax Act, for the following reasons. ...
TCC
Daville Transport Inc. v. The Queen, 2021 TCC 47
Canada, 2007 TCJ No. 273, that the Minister should have considered on a common sense basis, “what did the supplier supply?” ...
TCC
Mary Jane Stephens and the Estate of William R. Stephens v. Minister of National Revenue, [1988] 1 CTC 2249, 88 DTC 1170
On the other hand some of her other evidence must be considered. After her husband's death, investment difficulties and other differences arose between her and her son. ...
TCC
Eleanor B. Kushnir, Audrey N. Maclean, Peter L. Hartman, Ben Bauer v. Minister of National Revenue, [1986] 1 CTC 2514, 86 DTC 1381
He said that it was his practise in dealing with parents of children he examined to mask the true nature of the problem identified because of what he considered potential harm. ...
TCC
The Estate of the Late John N Gladden v. Minister of National Revenue, [1984] CTC 2243, 84 DTC 1242
. — No Canadian cases have yet considered the deemed disposition provisions of subsection 70(5). ...