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After quoting (at para.55) the statement in Sattva that “While the surrounding circumstances are relied upon in the interpretive process, courts cannot use them to deviate from the text such that the court effectively creates a new agreement,” noting (at para. 66) that “For a debt to be incurred, there must be an obligation to pay the amount of the debt,” and further noting (at paras. 69-70) that under “the common law doctrine of contribution as it applies to the payment of a debt by a joint debtor … ‘[i]f a debtor pays more than his equal share, he has a right to contribution in respect of the excess’,” Owen J stated (at paras. 77-78): [T]he evidence is that as of July 31, 2010 the Appellant had paid no amount in respect of the principal amount of the Second Loan to BDC or to any other person for the benefit of 1207330. ...

. … In sum, I am of the view that the debt claim bequeathed to the Taxpayer was transferred to her on November, 12, 2008, being the date of death of Mr. ...

. … It is clear that, in the files in this case, the principles enunciated in the Jarvis case were followed. ...

She also noted (at para. 63): Brown [2013 FCA 111] … determined that documents seized in a criminal search could be admitted into evidence on the appeal of an assessment. ...

As a result … the penalty is in fact higher than 50%. As was pointed out [in McLeod v. ...

. … [N]o transformation or modification of much significance was made to the Triplex in order for the three units to be linked in some manner to each other. ...

Absent express direction to the contrary, undefined terms in a taxation statute must be interpreted according to their established and accepted legal meaning …. ...

Favel J stated (at paras. 50-51): While the record did not contain information stating that the Applicant explicitly requested an extension of time or that he provided the Minister with reasons for requesting an extension of time, Notices of Objection filed after the 90 day delay for objecting, but within the extension of time delay, have been interpreted as implicit applications to extend time …. ...

He stated (at para. 64, TaxInterpretations translation): [T]he simple fact of wishing to obtain a better price on the sale of the immovable is insufficient for concluding that a taxpayer was engaged in an adventure or concern in the nature of trade; a taxpayer engaging in a project carrying risk or having a commercial character is not necessarily carrying on a business …. ...

Smith J found that CO2 Technologies was “a corporation controlled, directly or indirectly in any manner whatever” by a public corporation (CO2 Public) and, thus, was not a Canadian-controlled private corporation (CCPC) – even before getting to the one-sided terms of the “research agreement” between the two corporations. ...