$227,000 which the taxpayer, a construction contractor, received on the termination of its contract was held to be an income receipt in light of: (1) the smallness of the payment in relation to the annual revenues of $10MM to $20MM of its business (a civil engineering division, which did not go out of business as a consequence of the cancellation); (2) the termination appeared to have been attributable to performance delays by the taxpayer and apparently was not wrongful; and (3) the payment was calculated only to cover the loss which the taxpayer had suffered, to the date of termination, on the contract.
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d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
339365
Extra import data
{
"field_legacy_header": "<a id=\"StRomuald\"></a><strong><em>St.-Romuald Construction Ltée v. The Queen</em></strong>, 88 DTC 6405, [1988] 2 CTC 324 (FCTD)",
"field_override_history": false,
"field_sid": "",
"field_topic_category": ""
}
"field_legacy_header": "<a id=\"StRomuald\"></a><strong><em>St.-Romuald Construction Ltée v. The Queen</em></strong>, 88 DTC 6405, [1988] 2 CTC 324 (FCTD)",
"field_override_history": false,
"field_sid": "",
"field_topic_category": ""
}