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I cannot view section 261 … as contemplating a rebate on an error caused by the author's own inattention and carelessness. ...

The Queen, 2016 TCC 73 (Informal Procedure)-- summary under Subsection 152(1.6) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1.6) receipt of notice of redetermination of loss by limited partner not relevant After finding that the presumption in s. 244(20), that notice to the general partner of an LP is notice to all the partners, is conclusive rather than rebuttable, so that a limited partner would not have succeeded even were she able to establish that she had not received notices of determination and redetermination of loss which had been received by the GP, Lafleur J went on to find that even if the s. 244(2) presumption were rebuttable, “the language of subsection 152(1.6) of the Act is clear – whether one or more limited partners have received the notice of determination or not is not relevant for the validity of a notice of determination issued in accordance with subsection 152(1.4) of the Act.” ...

. … The amendment limits the amount by which the amalgamated company may bump the cost of any qualifying partnership interest held by the subsidiary. ...

. … As a result of subsection 204.3(2), the limitation periods in subsection 152(3.1) apply to Part X.1, with modification. ...

In finding that the appellant had continued to be a “registrant,” so that ss. 171(3)(b) and 200(2) did not apply, Favreau J referenced s. 141.1(3) and stated (at paras 57- 60, TaxInterpretations translation): The sale of equipment following the cessation of normal daily activities is … part of what the ETA terms "commercial activity". ...

. … It is in the vineyard where most of the employees are hired, where most of the equipment is required and used, where the labour expenses are the highest, and where the majority of the acreage is used. ...

Miller J found that the quoted definition of " freight transportation service" required that the property be carried by some mode of transport such as a vehicle, ship or rail car and that merely driving a car did not qualify as transporting it, stating (at para. 29) that: [T]he vehicle cannot be both the personal property and the means of carrying it at the same time. ...

. … [T]he words “with all due dispatch”, as set out in section 152(1)…, have no bearing on this analysis. ...

Accordingly, in dealing with the ETA equivalent (s. 325(1)) of ITA s.160, she found that ½ of the amounts drawn down under the line of credit to fund the husband's company constituted an advance by the wife of money borrowed by her, so that ETA s. 325 did not apply when her husband later transferred real estate to her to pay down that advance. ...

The Queen, 2017 TCC 164-- summary under Subsection 169(1) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(1) criminal defence fees incurred to protect reputation rather than re suspended business Operations at an individual’s swimming school were suspended as a result of charges brought against him respecting alleged misconduct with a 15-year old female instructor – and he incurred significant fees in obtaining an acquittal. ...