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Favel J found that the taxpayer had implicitly requested the Minister for an extension pursuant to s. 166.1 of the time for objecting, stating (at para. 50): Notices of Objection filed after the 90 day delay for objecting, but within the extension of time delay, have been interpreted as implicit applications to extend time …. ... Rather, the Minister remained passive for two years …. The Minister’s analysis of delays imputable to the CRA is limited to those incurred between the TCC order of February 26, 2013 and the assignment of the Applicant’s file to an appeal officer in November 2013, and consequently, at the initial level, cancelled interest for one month during that period (October 2013) to account for the delay. ...

On January 4, 2011, the taxpayer filed a Notice of Appeal respecting losses from the Sierra Trinity transactions – but due to an error, also disputed the disallowance of the Trinity Denton losses (because new counsel were unaware of the 1994 settlement). ... Finally, Strickland J noted (at para 119): … [T]he Third Reassessment, undertaken on December 19, 2014, fell outside the March 4, 2014 limitation period expiry and could not extend, restart or revive the exhausted limitation period. ...

After having indicated (at para. 23) that the reasonableness of the letters turned on a test of whether there may be considered to be “a rational connection … between the information sought and the administration and enforcement of the ITA,” Fothergill J rejected a submission that the request letters sought foreign-based information and that they should have been issued under s. 231.6, stating (at paras. 37, 43): I am satisfied that Dr. ... Smith personally.... … I am not persuaded that the evidence in this case is so compelling that it was unreasonable for the Minister to proceed otherwise than under s. 231.6 of the ITA. ...

The Minister denied the companies’ applications for relief from interest and penalties accrued during their 2014 through 2020 taxation years, made on the basis of “extraordinary circumstances leading to … financial hardship.” ... Otherwise, relief was denied largely on the basis that “the director remained responsible to take the necessary measures … to ensure that all obligations [were] met when required” and failed to do so, and also relief was denied under the financial hardship ground as the appropriate financial arrangements to pay the arrears including borrowing and restructuring finances to retire the debt had been made. ...

. … In the absence of a complete and convincing argument demonstrating that sections 152(3.4), 164(1)(b) and 125.7(5) of the ITA, considered together, defeat the interpretation proposed by Lemay based on the Minister having the discretion to accept the filing of an amended prescribed form, the defendant has therefore not discharged its burden of demonstrating that it is clear and obvious that the interpretation proposed by Lemay has no reasonable chance of acceptance …. ...

The Queen, 92 DTC 6595, [1993] 1 CTC 21 (FCTD)-- summary under Resolving Ambiguity Summary Under Tax Topics- Statutory Interpretation- Resolving Ambiguity Rothstein J. articulated various principles of the "modern, interpretative approach to the Income Tax Act " including the following principle: The Act should be applied as to affect the conduct of a taxpayer which has the designed effect of defeating the expressed intention of Parliament. ...

Stankovic, 2018 FC 462-- summary under Stare Decisis Summary Under Tax Topics- General Concepts- Stare Decisis Quebec CA decision relied upon In briefly disposing of the taxpayer's Charter arguments, Russell J stated (at para. 64): The issues raised by the Applicant on this point were addressed … by the Quebec Court of Appeal [Berger, 2016 QCCA 226]. ...

Minister of National Revenue, 91 D.T.C 5310, [1991] 1 CTC 68 (FCTD)-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence "... ...

Loewen, 93 DTC 5109, [1993] 1 CTC 212 (FCTD)-- summary under Subsection 39(4) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(4) In finding that a purported election made by the taxpayer only after an audit by Revenue Canada was invalid, Dubé J. stated (p. 5115): "... ...

The Queen, 92 DTC 6305, [1992] 2 CTC 1 (FCTD)-- summary under Treaties Summary Under Tax Topics- Statutory Interpretation- Treaties "... ...