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The Queen, 2012 TCC 105-- summary under Section 67 Summary Under Tax Topics- Income Tax Act- Section 67 The taxpayer, a lawyer, was bilked of $400,000 by scam artists, posing as clients, who induced him to pay for "processing " fees in connection with the recovery of a supposed container in the Ivory Coast containing US$8.5 million of cash. ...

The amount paid to Deacur & Co. was a consequence of research and development which would already taken place. ...

Taylor, 84 DTC 6234, [1984] CTC 244 (FCTD)-- summary under Expressio Unius est Exclusio Alterius Summary Under Tax Topics- Statutory Interpretation- Expressio Unius est Exclusio Alterius " Prima facie the same words in different parts of the same Statute should be given the same meaning unless there is a clear reason for not doing so. ...

.'s Claim [1927] BY Int'l L156, at 162: "'... The decisions of principle of the highest courts of most countries continue to hold that neither the shareholders nor their creditors have any right to the corporate assets other than to receive, during the existence of the company, a share of the profits, the distribution of which has been decided by a majority of the shareholders, and, after its winding-up, a proportional share of the assets'. ...

.'s Claim [1927] BY Int'l L156, at 162: "'... The decisions of principle of the highest courts of most countries continue to hold that neither the shareholders nor their creditors have any right to the corporate assets other than to receive, during the existence of the company, a share of the profits, the distribution of which has been decided by a majority of the shareholders, and, after its winding-up, a proportional share of the assets'. ...

. … …[T]he letter…was an amendment to the estate's tax return and its effect was to amend the initial return. ...

In finding that the alimentary allowance was not "paid" by him for purposes of s. 60(b), and was not "received" by her for purposes of s. 56(1)(b), Garon J. stated (p. 1499): "... ...

In finding that the alimentary allowance was not "paid" by him for purposes of s. 60(b), and was not "received" by her for purposes of s. 56(1)(b), Garon J. stated (p. 1499): "... ...

.)-- summary under Subsection 238(2) Summary Under Tax Topics- Income Tax Act- Section 238- Subsection 238(2) " [M]ens rea, in the traditional sense is not an essential ingredient of the offence of failing to remit money deducted from the wages of employees pursuant to Section 153. ...

The Queen, 2015 TCC 39-- summary under Subsection 169(2.1) Summary Under Tax Topics- Income Tax Act- Section 169- Subsection 169(2.1) Minister was presumed to understand the scope and quantum of issues that had been raised during audit Boyle J found that all that is required respecting issue identification is that the Minister (as opposed to a third party, such as a Tax Court Justice) "be able to understand the scope and quantum of the issue from its description in the notice of objection" – so that it was sufficient for the notice of objection to reference a description of the issues previously provided to CRA. ...