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I.       Overview [1]              The issue in this appeal is whether the Appellant, Mr. ... Hogan DATE OF JUDGMENT: March 2, 2015   APPEARANCES:   For the Appellant: The Appellant himself Counsel for the Respondent: Craig Maw Roxanne Wong   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: William F. ... No. 881 (QL) (FCA). [5]   Ibid. at p. 5416 DTC, para. 37 (QL). [6]   2011 FCA 142, [2013] 1 F.C.R. 86, 2011 G.S.T.C. 74. [7]   Ibid. at paras. 34-35. [8]   2004 SCC 68, [2004] 3 S.C.R. 461. [9]   Buckingham, supra note 6 at para. 38. [10]             Ibid. [11]             Ibid. at para. 39. [12]             Ibid. at para. 40. ...

Webb” Webb, J.           Citation: 2010TCC325 Date: 20100615 Docket: 2007-4122(IT)G   BETWEEN: CHI-LUEN HO, Appellant, and   HER MAJESTY THE QUEEN, Respondent.     ... Signed at Ottawa, Canada, this 15 th day of June, 2010.         “Wyman W. Webb” Webb, J.   Schedule “A”     Agreed Statement of Facts     1.                   ...

“François Angers” Angers J.       Translation certified true on this 20th day of February 2008.         François Brunet, Revisor       Citation: 2007TCC597 Date: 20071116 Docket: 2005-864(GST)G   BETWEEN: STYLE AUTO G.J., Appellant, and   HER MAJESTY THE QUEEN, Respondent.   ... “François Angers” Angers J.       Translation certified true on this 20th day of February 2008.         ...

Bowie” Bowie J.           Citation: 2008 TCC 544 Date: 20080926 Docket: 2007-4329(IT)I BETWEEN: MARILYN JAHNKE, Appellant, and   HER MAJESTY THE QUEEN, Respondent.   ...   [4]           Ibid, at para. 26.   [5]           [1925] S.C.R. 45.   [6]           [1948] S.C.R. 486 ...   [7]           R.S.C. 1985, c. T-2.   [8]           S.O.R./93-12.   [9]           S.S. 1989-90, c. ...

The Queen, 2007 TCC 739 (Informal Procedure)       Docket: 2006-3665(GST)I BETWEEN: MICHEL SCHOEB, Appellant, and   HER MAJESTY THE QUEEN, Respondent. ... Signed at Ottawa, Canada, this 7th day of December 2007.     “Lucie Lamarre” Lamarre, J.   ...   [15]     Accordingly, the appeal is allowed.   Signed at Ottawa, Canada, this 7th day of December 2007.   ...

  [13]     I quote a few paragraphs from that letter:   [TRANSLATION]               We hereby wish to advise you that we have assessed your case under        An Act to facilitate the payment of support.               ... For the year 2001: ·         Tuition fees of $187. ·         Education amounts of $480. ·         Medical expenses of $470. ·         Eligible donations of $5 ... Signed at Ottawa, Canada, this 18th day of June 2007.       “Louise Lamarre Proulx” Lamarre Proulx J.     ...

costs;   AND UPON reading the material filed and hearing submissions from counsel for the Appellant and counsel for the Respondent;     THIS COURT ORDERS THAT:   1.       ... Factor 6 – Whether the Trial is by Judge or Jury: [47]         This factor is not relevant in Tax Court appeals. ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

I quote from paragraph 33, where Justice Mainville indicated that: (…) the burden is on the directors to prove that the conditions required to successfully plead such a defence have been met. (…) The directors must thus establish that they exercised the degree of care, diligence and skill required “ to prevent the failure ”. ... Leckie   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

Reasons for Judgment Lamarre Proulx, J.T.C.C. [1] These are appeals concerning the deduction of rental losses for the 1993, 1994 and 1995 taxation years. [2] In making reassessments, the Minister of National Revenue (the "Minister") relied on the facts set out in paragraph 12 of the Reply to the Notice of Appeal (the "Reply") as follows: [TRANSLATION] (a) during the years in issue, the appellant was the owner of the property located at 890, 892 and 894 St-Édouard Street in St-Jude, in the Province of Quebec (hereinafter the "property"); (b) on July 12, 1996, the appellant informed the Minister that the initial purpose in purchasing the property had been to provide his children with living accommodations; (c) the appellant also informed the Minister that he had used advertisements at the "video club" and "word of mouth" in renting his units; (d) for the 1993, 1994 and 1995 taxation years, the appellant reported the following rental income and expenses: Description 1993 1994 1995 Income: $3,150 $3,000 $3,875 Expenses: Taxes $1,556 $1,206 $1,225 Electricity $ 850 $ 883 $ 773 Insurance $ 953 $ 963 $1,516 Interest/mortgage $6,622 $5,902 $6,241 Maintenance/repairs $1,993 $ 134 $1,152 Subtotal $11,974 $ 9,088 $10,907 NET LOSS ($ 8,824) ($6,088) ($ 7,032) (e) the fixed costs alone totalled $9,981 in 1993, $8,954 in 1994 and $9,755 in 1995; (f) the appellant has incurred the following net losses over the past years: Year Net loss 1991 $10,630 1992 $10,002 1993 $ 8,824 1994 $ 6,088 1995 $ 7,032 (g) during the years in issue, 894 St-Édouard Street was used by the appellant, who owned a video club; (h) during the years in issue, the appellant reported a monthly rent for 894 St-Édouard Street of $100, which was far less than fair market value; (i) the Minister's examination of the video club's books showed that the rents referred to in paragraph (h) above were never paid to the appellant; (j) for the 1993 and 1994 taxation years, the appellant gave 890 St-Édouard, St-Jude as his personal address on his income tax returns; (k) during the years in issue, the property was leased by the appellant's children at a price below fair market value; (l) during the years in issue, 892 St-Édouard Street was not rented; (m) consequently, there was no expectation of profit from leasing the property; (n) during the years in issue, the appellant was thus unable to show that the expenses of $8,824 for the 1993 taxation year, $6,088 for the 1994 taxation year and $7,032 for the 1995 taxation year were incurred for the purpose of gaining or producing income from a business or property. [3] The witnesses were the appellant himself and Robert Lévesque. ...

Smith” Smith J.           Citation: 2016 TCC 6 Date: 20160106 Docket: 2014-1385(IT)I BETWEEN: ELLEN LEIBOVICH, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... He was viewed as “ an eligible candidate ”. [15]         J never attended Vanguard. ... Smith DATE OF JUDGMENT: January 6, 2016   APPEARANCES:   Agent for the Appellant: Charles Leibovich     Counsel for the Respondent: Sara Jahanbakhsh   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: William F. ...