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The Queen, 2014 TCC 130                                                                                                                   2014 TCC 130 Court File No. 2010-619(GST)G                                                                                TAX COURT OF CANADA   BETWEEN:                    ONTARIO COLLEGE OF TEACHERS                                                  appellant                           - and-                       HER MAJESTY THE QUEEN                                                 respondent                   TRANSCRIPT OF REASONS FOR JUDGMENT           FROM THE HONOURABLE MR. JUSTICE JORRÉ                  Federal Judicial Centre 180 Queen Street West, Toronto, Ontario           on Friday, March 28, 2014 at 3:00 p.m.       ... Yuan                                 Brandon Siegal                                            Firm:              McCarthy Tétrault                                Toronto, Ontario       For the respondent:         William F. ...

the Amended Reply for each of the two Appeals;                                                             iii.       ...       [31]          The Applicants’ factum shall be filed and served 30 days prior to the scheduled hearing date. ... Tyron Counsel for the Respondent: Michael Taylor Raj Grewal   COUNSEL OF RECORD: For the Appellant: Name:     Firm:     For the Respondent: Nathalie G. ...

Woods” Woods J.       Citation: 2014 TCC 267 Date: 20140905 Dockets: 2013-2800(CPP) 2013-2801(EI)   BETWEEN:   MICHELLE POROTTI, Appellant, and   THE MINISTER OF NATIONAL REVENUE, Respondent.   ... Woods DATE OF JUDGMENT: September 5, 2014   APPEARANCES:   For the Appellant: The Appellant herself   Counsel for the Respondent:   Holly Popenia   COUNSEL OF RECORD: For the Appellant: Name: N/A   Firm:   For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Ontario     ...

Assessment – audit – reassessment [10] The Appellant was assessed for the 1991 taxation year on the basis that he was entitled to a deduction for the ABIL as claimed in his return. ... The ABIL to which the Appellant is entitled, therefore, is properly computed as: 100 shares at $1.00 each    $100.00 paid to the bank $213,949.18 less recovered from Locke 48,463.50 165,485.68 removal expenses 52,892.84 total    218,478.52 ABIL = 0.75 x $218,478.52 = $163,858.89 This is $689.11 less than the amount claimed by the Appellant. ... Bowie" J.T.C.C. [1]           Exhibit R-8, supra. [2]            [1983] 1 S.C.R. 29 at 39. ...

Carphin, his spouse, and a Canadian corporation owned by them, Van Merlin Consulting Ltd. (“ Van Merlin ”). [12]         The CRA auditor concluded that Mr. ... Factual background A.      The evidence [19]         The Crown’s witnesses consisted of two employees of the CRA, Michael Weevers and Winnie Lin. [20]         Mr. ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

Paris” Paris J.           Translation certified true         on this 20th day of January 2015. ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

The approach to s. 245 of the Income Tax Act may be summarized as follows.         1.    ... The burden is on the taxpayer to refute (1) and (2), and on the Minister to establish (3).        3.    ... On September 1, 1994, the following transactions occurred:                  (i)       the Transfer/Deed of Land, showing the Appellant and Jordanna Lipson as joint tenants, was registered;                  (ii)       the Charge/Mortgage of Land was registered;                  (iii)      the Appellant's solicitor used the funds received from the Appellant on August 31, 1994 to pay $562,500 towards the purchase price of the Property;                  (iv)      the Bank advanced $562,500 to the Appellant's solicitor in trust as proceeds from the mortgage on the Property;                  (v)      the Appellant's solicitor used the $562,500 proceeds from the mortgage to repay Jordanna Lipson's loan from the Bank; 13.     ...

Mercia was an employee for purposes of the Canada Pension Plan (“ CPP ”) and Employment Insurance (“ EI ”) legislation. ... Miller DATE OF JUDGMENT: May 5, 2015   APPEARANCES:   Agent for the Appellant: Michael Manko Counsel for the Respondent: Jeff Watson   COUNSEL OF RECORD: For the Appellant: Name: n/a   Firm:   For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada     [1]           2001 SCC 59.   ...

As illustrated by that table, the amounts of Part X.1 tax assessed by the CRA for 2006 and 2011 through 2013 were less than the amounts of Part X.1 tax calculated by the Court.       ... Sommerfeldt DATE OF JUDGMENT: August 31, 2017   APPEARANCES:   For the Appellant: The Appellant himself Counsel for the Respondent: Derek Edwards   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: Nathalie G. Drouin Deputy Attorney General of Canada Ottawa, Canada     [1]           Income Tax Act, RSC 1985, c. 1 (5th supplement), as amended. [2]               Mr. ...

−        Does the applicant meet the conditions set out in subsection 304(5) of the ETA? ... No one is challenging the fact that the one-year time limit was respected.           304(5)(b)(i) [37]         The applicant must establish that within the time limited for objecting, −        it was unable to act or to give a mandate to act in its name, or [38]         The applicant is deemed to have received the notice of assessment dated June 3, 2013, pursuant to subsection 334(1) of the ETA. ... Fournier told her to wait for the assessment. −        lack of evidence; past actions of the applicant [47]         In her testimony, Ms. ...