Dionne v. R., [1998] 2 C.T.C. 2352 -- text
Tremblay T.C.J.:
1 This appeal was heard under the informal procedure at Trois-Rivières, Quebec, on April 9, 1997.
Tremblay T.C.J.:
1 This appeal was heard under the informal procedure at Trois-Rivières, Quebec, on April 9, 1997.
Bowman T.C.J.:
1 These appeals are from assessments made under the Income Tax Act for the appellant's 1986, 1987, 1988, 1989 and 1990 taxation years. In those years, the appellant claimed to set off against capital gains, net capital losses which he claims he sustained in 1982.
Garon T.C.J.:
1 These are appeals from income tax assessments for the 1991, 1992 and 1993 taxation years in the case of the Appellant Larry Chartrand and appeals from the income tax assessments for the taxation years 1992 and 1993 in the case of the Appellant Lorraine Chartrand. By the reassessments, the Minister of National Revenue disallowed rental losses claimed by both Appellants in the years in issue.
2 These appeals were heard on common evidence.
Dussault T.C.J.:
Marceau J.A.:
1 This appeal and cross-appeal arise from a ruling made by a Tax Court of Canada judge on a motion for an order requiring the Crown to produce documents for discovery in the course of the appellant's appeal proceedings against a reassessment by the Minister of National Revenue of its 1992 income tax liability.
Brulé T.C.J.:
1 The appellant, Multiview Inc. is appealing a reassessment of the Minister of National Revenue (the “Minister”) whereby the Minister disallowed the appellant's claim for the refundable Scientific Research & Experimental Development (“SR & ED”) credit in the amount of $505,830.00 in the 1994 taxation year.
Christie A.C.J.T.C.:
1 The issue to be determined is whether this Court has jurisdiction to extend the time within which Nasha Properties Ltd. (“Nasha”) may serve on the Minister of National Revenue (“the Minister”) Notices of Objection to assessments of liability for income tax in respect of its 1987 and 1988 taxation years.
Tremblay T.C.J.:
1 This appeal was heard at Québec City, Quebec, on January 15, 1997. The last written argument was filed on April 14, 1997.
Gibson J.:
1 The applicant seeks judicial review of a notice of assessment of excise duty, penalties and interest, as amended, made against it pursuant to the Excise Act.The original notice of assessment is dated the 30th of May, 1996. It was amended the 16th of July, 1996 and further amended the 15th of November, 1996. The relief requested is that the assessment, as amended, be declared invalid or unlawful and that it be quashed or set aside. In addition, the applicant seeks costs.