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TCC

Collins v. R., [1998] 4 CTC 2037

I have considered the submissions made and the evidence and I cannot find any valid legal reason to conclude that these expenses are somehow deductible in 1992. ...
TCC

Dwinnell v. R., [1998] 4 CTC 2228

This is more so when the adjusted figures below are considered. (b) The mortgage had to be increased for the unforeseen reasons discussed above. ...
FCA

Binjamin v. Canada, 2022 FCA 164

The Tax Court Judge found that the appellant provided no credible explanation for the amounts of unreported sales revenue reflected in the reassessments. [5] The Tax Court Judge considered the concessions made by the appellant’s representative, the oral testimony of an auditor and the appellant, as well as documentary evidence. ...
FCTD

In Re the Income Tax Act and in Re One or More Assessments by the Minister of National Revenue Pursuant to One or More of the Following Statutes; The Income Tax Act, the Canada Pension Plan and the Employment Insurance Act v. 2959-4660 Québec Inc. (Doing Business From Time to Time Under the Name and Trade Name “Alarme La Providence”), Judgment Debtor and Honeywell Limited, Garnishee, [1999] 4 CTC 344, 99 DTC 5335

.), the Court of King’s Bench considered whether judicial compensation granted by the court in the exercise of its discretionary authority only existed by virtue of a judgment or whether it should be retroactive to the date of the principal claim or of the counterclaim. ...
TCC

Kroeker v. R., [1999] 4 CTC 2045, 99 DTC 1250

Rankin, and the changes in American tax law had a negative and unexpected impact on the business, no evidence was presented to show what profit the taxpayer might have earned had these events not occurred and whether the amount would have been considered substantial when compared to his professional income. ...
TCC

Robichaud v. R., [1999] 4 CTC 2654, 99 DTC 41

This procedure does not meet the requirements laid down by the Act for support payments to be considered deductible. ...
TCC

Forget-Blanchard v. R., [1999] 4 CTC 2769

In 1991, Parliament clarified its position by defining the meaning of the expression “basic activities of daily living”: 118.4(1) For the purposes of subsection 6(16), sections 118.2 and 118.3 and thi# subsection, (a) an impairment is prolonged where it has lasted, or can reasonably be expected to last, for a continuous period of at least 12 months; (b) an individual’s ability to perform a basic activity of daily living is markedly restricted only where all or substantially all of the time, even with therapy and the use of appropriate devices and medication, the individual is blind or is unable (or requires an inordinate amount of time) to perform a basic activity of daily living; (c) a basic activity of daily living in relation to an individual means (i) perceiving, thinking and remembering, (ii) feeding and dressing oneself, (iii) speaking so as to be understood, in a quiet setting, by another person familiar with the individual, (iv) hearing so as to understand, in a quiet settling, another person familiar with the individual, (v) eliminating (bowel and bladder functions), or (vi) walking; and (d) for greater certainty, no other activity, including working, housekeeping or a social or recreational activity, shall be considered as a basic activity of daily living. ...
TCC

Ron Miller Realty Ltd. v. R., [1999] 4 CTC 2858, 99 DTC 1192

The only item at issue is whether this appeal should be considered a Class “A” or a Class “B” action, for the purposes of determining costs. ...
FCTD

Gene a Nowegijick v. Her Majesty the Queen, [1979] CTC 195, 79 DTC 5115

The authorities pertinent to the foregoing were recently considered by Thurlow, ACJ, and need not be recited here.t [4] It was not argued that the fact the services by which the wages were earned were performed off the Gull Bay Reserve is determinative of anything. ...
FCA

Harold P Connor v. Her Majesty the Queen, [1979] CTC 365, 79 DTC 5256

In his use of the term “over-optimism” he had reference to the projections of earnings of Halifax Parking Limited made by the appellant’s experts which clearly he considered to have been in each case exaggerated. ...

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