Paragraph 3(a)
Cases
Hay v. The Queen, 91 DTC 5258 (FCTD)
A post master breached the Public Money and Property Safeguards Regulations in cashing cheques made out to the Receiver General for Canada...
Chhabra v. The Queen, 89 DTC 5310, [1989] 2 CTC 13 (FCTD)
The taxpayer was able to demonstrate that the unrelenting and overzealous collection activities of Collections officials in the Halifax office of...
Weinkauf v. The Queen, 85 DTC 5570, [1985] 2 CTC 354 (FCTD), briefly aff'd [1988] 1 CTC 231 (FCA)
A possibly negligent audit of the taxpayer was not the real and proximate cause of damages which the taxpayer later suffered as a result of...
384238 Ontario Limited v. The Queen, 84 DTC 6101, [1984] CTC 523 (FCA)
It is no defence to an action in trespass against the Crown for wrongful seizure of the taxpayer's chattels that the seizure of the chattels was...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Estoppel | 79 |
Stephens Estate v. The Queen, 82 DTC 6132, [1982] CTC 138 (FCA)
It was found that the seizure of the taxpayer's chattels on his premises under a writ of fi. fa. by a sheriff, while accompanied and under the...
Portage Tax Services v. The Queen, 82 DTC 6104, [1982] CTC 95 (FCTD)
The Crown was liable for damages for the negligence of Revenue Canada employees in paying tax refunds to the taxpayers rather than the registered...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 164 - Subsection 164(3) | 48 |
Section 8
Cases
384238 Ontario Ltd. v. The Queen, [1981] CTC 295, 81 DTC 5215 (FCTD), aff'd 84 DTC 6101 (FCA)
S.3(a) refers only to liability in respect of a tort committed by "a servant of the Crown", and S.3(6) would accordingly appear to protect the...
Sinha v. The Queen, 82 DTC 6125 (FCTD)
S.8 preserves the Crown's former immunity in respect of anything done or omitted in the exercise of a statutory power or authority. Accordingly, a...
Section 32
Cases
Peter Kirkwood Holdings Ltd. v. Canada, 2004 DTC 6035, 2003 FCA 481
In rejecting a submission that the Minister was statute barred from proceeding against the taxpayer because of the expiry of the two-year...
Markevich v. Canada, 2003 DTC 5185, 2003 SCC 9, [2003] 1 S.C.R. 94
Section 32 of the Crown Liability and Proceedings Act applied to prohibit the taking of collection action against the taxpayer six years after a...