![Federal Court of Appeal header and the Canadian coat of arms](/fca-caf/decisions/en/62838/95690/res.do)
Date:
20130919
Docket:
A-553-12
Citation:
2013 FCA 221
CORAM: SHARLOW
J.A.
STRATAS
J.A.
NEAR
J.A.
BETWEEN:
|
NRT TECHNOLOGY
CORP.
|
Appellant
|
and
|
HER MAJESTY THE
QUEEN
|
Respondent
|
Heard
at Toronto, Ontario, on September 19, 2013.
Judgment
delivered from the Bench at Toronto, Ontario, on September 19, 2013.
REASONS FOR JUDGMENT OF THE COURT
BY: SHARLOW J.A.
![Federal Court of Appeal header and the Canadian coat of arms](/fca-caf/decisions/en/62838/95689/res.do)
Date:
20130919
Docket:
A-553-12
Citation:
2013 FCA 221
CORAM: SHARLOW
J.A.
STRATAS
J.A.
NEAR
J.A.
BETWEEN:
|
NRT TECHNOLOGY CORP.
|
Appellant
|
and
|
HER MAJESTY THE
QUEEN
|
Respondent
|
REASONS FOR JUDGMENT
OF THE COURT
(Delivered
from the Bench at Toronto, Ontario, on September 19, 2013)
SHARLOW J.A.
[1]
This
is an appeal of a judgment of Justice Campbell Miller of the Tax Court of Canada
dismissing an appeal of a reassessment under the Income Tax Act, R.S.C.
1985, c. 1 (5th Supp.) for the 2007 taxation year (2012 TCC 420).
The issue is whether the appellant, NRT Technology Corp.,
Page:
3
is entitled to a deduction for
certain pre-2007 non-capital losses of a corporation it acquired in 2006 with
which it was subsequently amalgamated.
[2]
Despite
the able submissions of counsel for NRT, we have been unable to discern any
error of law or fact on the part of Justice Miller.
[3]
The
appeal will be dismissed with costs.
“K. Sharlow”
FEDERAL COURT OF
APPEAL
NAMES OF COUNSEL AND
SOLICITORS OF RECORD
DOCKET: A-553-12
APPEAL FROM AN ORDER OF THE
HONOURABLE JUSTICE CAMPBELL J. MILLER OF THE TAX COURT OF CANADA DATED NOVEMBER
30, 2012, IN COURT FILE NO. 2010-1901 IT(G).
DOCKET:
|
A-553-12
|
STYLE
OF CAUSE:
|
NRT TECHNOLOGY CORP. v.
HER MAJESTY THE QUEEN
|
PLACE OF HEARING: TORONTO, ONTARIO
DATE OF HEARING: SEPTEMBER
19, 2013
REASONS FOR JUDGMENT
OF THE COURT BY: SHARLOW
J.A.
STRATAS J.A.
NEAR
J.A.
DELIVERED FROM THE
BENCH BY: SHARLOW
J.A.
APPEARANCES:
David
Chodikoff
Tarsem
Basraon
|
FOR
THE APPELLANT
|
Rita
Araujo
Arnold Bornstein
|
FOR
THE RESPONDENT
|
SOLICITORS
OF RECORD:
Miller
Thompson LLP
Toronto, Ontario
|
FOR THE APPELLANT
|
William F. Pentney
Deputy Attorney General of Canada
|
FOR THE RESPONDENT
|