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

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. ...

The Queen, 2014 DTC 1216 [at at 3872], 2014 TCC 309-- summary under Stare Decisis Summary Under Tax Topics- General Concepts- Stare Decisis weight of obiter depends on fulness of argument Before finding that the taxpayers' argument was contradicted by the "authoritative obiter " in S.T.B. that s. 245(7) applied to third parties only, Hogan J paraphrased (at para. 28) R. v. ...

The Queen, 2014 DTC 1216 [at at 3872], 2014 TCC 309-- summary under Stare Decisis Summary Under Tax Topics- General Concepts- Stare Decisis weight of obiter depends on fullness of argument Before finding that the taxpayers' argument was contradicted by the "authoritative obiter " in S.T.B. that s. 245(7) applied to third parties only, Hogan J paraphrased (at para. 28) R. v. ...

MNR, 93 DTC 50, [1992] 2 CTC 2596 (TCC)-- summary under Subsection 15(2) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2) 15(2) not contrary to Charter In finding that the inclusion of the amount of a loan made to the taxpayer by a corporation owned by his father in the taxpayer's income was not contrary to s. 15(1) of the Charter, Watson D.J. stated (p. 53): "... the purpose of subsection 15(2) is to prevent the de facto tax-free distribution of corporate funds to shareholders. ...

The Queen, 93 DTC 1004, [1993] 2 CTC 2259 (TCC)-- summary under Subsection 245(3) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(3) Before going on to find that the former s. 245(1) did not prohibit the deduction of interest by the taxpayer, Bowman J. stated, in obiter dicta that: "... ...

MNR, 93 DTC 1473, [1993] 2 CTC 3148 (TCC)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) In finding that interest costs incurred by the taxpayer to finance the payroll cost of its R & D personnel were described in s. 20(1)(c), Kempo, TCJ. stated (p. 1478): "That no income was or could have been gained or produced at that time from the property being researched and developed is not determinative because the purpose and direct use of the borrowed funds were focused to that end and no issues were raised concerning the efficacy of the projects under research. ...

Lamarre J. stated (at p. 2119): "... The seminars in question herein can very well be defined as formal meetings of members of an organization (Amway) that are held for business purposes and that result in the acquisition of knowledge by those attending them. ...

Mogan TCJ. stated (p. 1257): "... if a reserve is in fact claimed and allowed in a particular taxation year, the legality of the allowance is not material and the amount that was in fact deducted must be included in computing the income for the immediately following year". ...

" the taxpayer to whom reference is made in s. 1204(1)(b), rather than referring to "... the oil and gas business, the production of it... ...