Létourneau, J.A.:—The Court has before it two applications for judicial review made pursuant to sections 28 and 18.1 of the Federal Court Act[1] and brought against a Tax Court of Canada decision rendered orally in May 1992. That Court heard two appeals filed by the applicants from a notice of assessment sent to them by the Minister or National Revenue.
Pinard, J.:—This is an appeal under section 81.22 of the Excise Tax Act. R.S.C. 1985, c. E-15, as amended (the "Act"), which permits a person to appeal to this Court in respect of an assessment or determination by the Minister
Pinard, J.:—This is an appeal under section 81.22 of the Excise Tax Act. R.S.C. 1985, c. E-15, as amended (the "Act"), which permits a person to appeal to this Court in respect of an assessment or determination by the Minister of
MacGuigan, J.A. (orally):—The leading case with respect to the deduction of farming losses from income from another source is Moldowan v. The Queen, [1978] 1 S.C.R. 480, [1977] C.T.C. 310, 77 D.T.C. 5213, per Dickson,
Reed, J.:—The issue in this case is whether the day of mailing of a notice of original assessment of the income tax payable by Paramount Pictures Corporation (Canada) Ltd. for the fiscal year ending July 31, 1980, occurred in 1981 or in 1984. If it
Hugessen J.A.:—This is an appeal from a decision of Reed, J. in the Trial Division dismissing an appeal from a decision of Mogan, T.C.C.J. in the Tax Court of Canada which, in turn, had dismissed the taxpayer's appeal from the Minister's
Robertson, J.A.:—The appellant maintains that he is entitled to a tax-free capital gain on the sale of his home and surrounding lands encompassing 8.99 acres. For the most part, the legal issues to be addressed herein are of little relevance to
Heald, J.A.:—We have been unable to identify any possible grounds upon which the Court would be entitled to interfere with the decision of the learned Tax Court judge herein.
Jerome A.C.J. :—This is an appeal by the Crown from a decision of the Tax Court of Canada, dated January 25, 1990 [Phillips v. M.N.R., [1990] 1 C.T.C. 2372, 90 D.T.C. 1274], wherein it was held that moneys received by
Jerome, A.C.J.:—This is an appeal by the Crown from a decision of the Tax Court of Canada dated March 19, 1990, wherein it was held that moneys received by the defendant from his employer, in connection with his relocation from Edmonton to
