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T Rev B decision

Jean Guay v. Minister of National Revenue, [1973] CTC 2279, 73 DTC 224

Although he was obliged, by the Superior Court judgment, to house his wife and children in the said home and to make the said payments, these expenses were of benefit to the appellant himself and cannot be considered to be expenses for the maintenance of ‘his wife and children; in my opinion they represent personal or living expenses, which are not deductible. ...
T Rev B decision

Precision Automotive Company Limited v. Minister of National Revenue, [1972] CTC 2349, 72 DTC 1283

Having considered all the evidence as a whole, I find both in fact and in law that the amounts paid or credited to Mrs Wosnick and Mrs Dicker were in fact earned by Mintz and Dicker, and that the $10,000 in bonuses ($5,000 each) credited to Mintz and Dicker on the books of the appellant company was for services rendered, pursuant to an understanding between the three principal shareholders; and that the sum of the balances standing to the credit of Mintz and Dicker as of March 31, 1964 was $9,246.14, which amount was part of the $130,000 paid to Mintz and Dicker in the final settlement. ...
T Rev B decision

Alfred Wallace Garrard v. Minister of National Revenue, [1972] CTC 2362, 72 DTC 1307

Appellant’s whole course of conduct convinced me that, in view of the statutory provisions and jurisprudence pertaining thereto, the appellant’s farm losses should be considered deductible and the appeal herein should be allowed. ...
T Rev B decision

Marilyn a Palmer v. Minister of National Revenue, [1972] CTC 2367, 72 DTC 1309

The obvious question in this case is: should the appellant be considered as subject to tax under the appropriate provisions of the Act on the ground that her husband was active in real estate, even though the evidence clearly indicates that most of his activities were unknown to the appellant and she had little real interest in his business affairs? ...
T Rev B decision

Morasch Builders & Supplies LTD v. Minister of National Revenue, [1972] CTC 2386, 72 DTC 1333

In my opinion, because of the course of conduct of the appellant company and that of its main shareholder, the gain under discussion should be considered taxable and, consequently, the appeal is dismissed. ...
T Rev B decision

DSBK Management Ltd. v. Minister of National Revenue, [1975] C.T.C. 2281, 75 D.T.C. 219

To engage the services of persons, professional or others, for performing any services considered as incidental to the powers of the company. 6. ...
T Rev B decision

P W Lavack Co. v. Minister of National Revenue, [1975] C.T.C. 2365, 75 D.T.C. 283

In that case the Minister contended that money borrowed for redemption of shares was certainly not to be considered as capital borrowed for the purpose of earning money, and that therefore the interest payable thereon could not be treated as a deductible expense. ...
T Rev B decision

Barki v. Minister of National Revenue, [1975] C.T.C. 2300, 75 D.T.C. 228

The appellant contends that the transaction should be considered as a whole and that the deductions which were permissible to him, as a resident of Canada, should also be permissible as a non-resident. ...
T Rev B decision

Beardmore v. Minister of National Revenue, [1975] C.T.C. 2030, 75 D.T.C. 31

Beardmore, on the other hand, claims that the amounts of $20 a month paid to her were not for her maintenance but were the reimbursement by her husband of advances made by her toward the payment of common debts and, as such, cannot be considered as income in her hands. 11 In attempting to determine the deductibility or otherwise of the $20 monthly payment made by Gordon R. ...
T Rev B decision

Leslie O Parnell v. Minister of National Revenue, [1978] CTC 2357, [1978] DTC 1271

Minister of National Revenue, [1978] CTC 2357, [1978] DTC 1271 Delmer E Taylor:—This is an appeal against income tax assessments in which the Minister of National Revenue increased the taxable income of the appellant by $5,649 and $13,182 for the years 1972 and 1973 respectively, the amounts being considered income and not capital receipts. ...

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