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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, 95 DTC 821, [1995] 1 CTC 2524 (TCC)-- summary under Subsection 152(5) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(5) Before going on to find that two reassessments issued following the normal reassessment period were void, Mogan TCJ. stated (at p. 826): "... subsection 152(5) does not by itself authorize the Minister to make a reassessment with respect to a particular taxation year. ...

Before noting that a technical interpretation of the Department of National Revenue contained an interpretation of s.17(3) which he had rejected, Bowman A.C.J. stated (at p. 299): "... departmental practice may be of assistance in resolving a doubt in favour of a taxpayer. ...

The Queen, 2010 DTC 5076 [at 6816], 2009 FCA 48-- summary under Subsection 37(2) Summary Under Tax Topics- Income Tax Act- Section 37- Subsection 37(2) The "research" the taxpayer contracted for with a Brazilian firm did not qualify as scientific research & experimental development under s. 248(1): it was not scientifically noteworthy, considering such factors as the lack of a novel scientific question, and the lack of rigour in the hypotheses, experiments, and records. ...

McArthur TCJ. stated (at p 1760): "... Appellants' description of the properties as capital is a statement of law and not fact. ...

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

Atkins, 76 DTC 6258 that while the: "... Court has the power to reconsider and refuse to follow one of its previous decisions, we are of opinion that we should do so only when we are convinced that our previous decision was wrong... ...

Body & Paint Shop" was not entitled to deduct capital cost allowance in respect of the cost of that right, Roland St-Onge stated (p. 204) that "the trade name of a firm is purely goodwill and cannot be construed as a depreciable asset". ...

.[:] "'... the words of an Act are to be read in their entire context and in their grammatical and ordinary sense harmoniously with the scheme of the Act, the object of the Act, and the intention of Parliament.'" ...