Search - 德国民法典第1993条

Did the Minister err in interpreting section 5 of the Remission Order in such a way as to deny the Applicant recovery of GST paid for the period 1991 to 1993? ... Mossop, [1993] 1 S.C.R. 554, [1993] S.C.J. No. 20 (QL); Housen v. Nikolaisen, [2002] 2 S.C.R. 235, 2002 SCC 33 "> 2002 SCC 33, [2002] S.C.J. ... Beblow, [1993] 1 S.C.R. 980, [1993] S.C.J. No. 36 (QL)). I agree that, in these circumstances, the Minister was enriched and the Applicant was correspondingly deprived. ...

The deductions claimed for 1992 and 1993 were to be reduced to $672 and $480. ... The applicant had failed to report a total of $15,000 in capital gains ($7,000 and $8,000) in 1993. ... The net federal tax payable was $7,603.36 for 1992 and $10,254.91 for 1993. ...

He failed to submit a Notice of Objection before November 4, 1993, as per subsection 165(1) of the Income Tax Act, R.S.C. 1985, c. 1 (5 th Suppl.) ... However, he was granted an extension of time and filed his objection on December 14, 1993. ... Kopps filed a third request to have the date of the loss carry back effective April 30, 1992 rather than November 4, 1993. ...

.: Reasons for Order This motion for an extension of time within which to appeal a 30 September 1993 order was heard and granted 9 December 1996. ... This synopsis, which is not exhaustive, but which summarizes the pertinent events, brings us to the present motion for an extension of time within which to appeal the 30 September 1993 order. ... We now turn to the issue of merit and whether the 30 September 1993 reasons of the trial judge are at least arguably wrong. ...

Canada (Customs and Revenue Agency), 2004 FC 176 Date: 20040202 Docket: T-1713-02 Citation: 2004 FC 176 Ottawa, Ontario, the 2nd day of February 2004 Present: The Honourable Madam Justice Danièle Tremblay-Lamer BETWEEN: MICHEL LAVIOLETTE Applicant and THE CANADA CUSTOMS AND REVENUE AGENCY and YVAN MARCEAU, in his capacity as Chief, Appeals Office, Taxation Services, Québec Respondents REASONS FOR ORDER AND ORDER [1]        This is an application for judicial review from a decision by the Canada Customs and Revenue Agency (the Agency) by which the applicant must pay costs, taxes and interest from September 13, 1995, for the 1992 taxation year and from February 21, 1996, for the 1993 taxation year, pursuant to the Income Tax Act, R.S.C. 1985, c. ... On February 21, 1996, it issued a notice of reassessment to the applicant for the 1993 taxation year charging interest on arrears, instalments and refunds amounting to $5,335.75. [3]        According to the new notices of assessment, the loss reported by a company in which the applicant had invested money for research and development was disallowed since the said company was not regarded as operating a business with an expectation of profit. [4]        On or about November 24, 1995, the applicant filed a notice of objection to these reassessments. [5]        In fall 1995, Revenue Canada made an offer to a large part of the taxpayers who had invested in doubtful projects (the first group). ... It also cancelled the interest for the period between July 5, 1994 and February 21, 1996 (the date of the second notice of assessment) for 1993, representing the sum of $8,043.97. [8]        On May 28, 2002, the applicant asked the Agency to reconsider his case once again. [9]        On September 16, 2002, the Agency notified the applicant it was cancelling another part of his interest on arrears, namely $2,857.22 for the period between May 1, 1993 and July 4, 1994, in respect of the 1992 taxation year and $339.10 for the period between May 1, 1994 and July 4, 1994, in respect of the 1993 taxation year. [10]      The applicant requested a review of this last decision by the Agency. ...

HARGRAVE PROTHONOTARY      This motion for an extension of time within which to appeal a 30 September 1993 order was heard and granted 9 December 1996. ... This synopsis, which is not exhaustive, but which summarizes the pertinent events, brings us to the present motion for an extension of time within which to appeal the 30 September 1993 order. ... We now turn to the issue of merit and whether the 30 September 1993 reasons of the trial judge are at least arguably wrong. ...

Nothing further occurred, save requests by the defendant for the plaintiffs affidavit of documents and one written response from the plaintiff, in November of 1993, saying that he was working on the affidavit. ... Bombardier Ltd. (1991), 48 F.T.R. 221, 37 C.P.R. (3d) 467, affirmed (1993), 48 C.P.R. (3d) 555, 153 N.R. 235 (F.C.A.) and Nichols v. ... However, the plaintiffs affidavit contains an honest admission that he has not pushed the case and indicates that he has suffered from chronic ill-health, at least during the period January 1993 through May 1995. ...

Mid-Plains Contractors Ltd., [1993] 1 C.T.C. 280, 93 D.T.C. 5391; Berg v. ... Canada, May 21, 1993 (MacLeod J.), Alta. Q.B. (unreported). Orsborn J. ... Mid-Plains Contractors Ltd., [1993] 1 C.T.C. 280, 93 D.T.C. 5391 (Sask. ...

By notice of motion dated April 8, 1993, the plaintiffs applied for leave to amend the statement of claim. ... On April 19, 1993, the Associate Senior Prothonotary allowed the application without reasons and the Minister filed a notice of motion on May 3, 1993 to appeal this decision. ... Canada, [1993] 1 C.T.C. 2306, 93 D.T.C. 298 (T.C.C.) at page 2309 (D.T.C. 301).) ...

The applicant's 1990 taxation year ending July 31, 1990 was assessed on January 17, 1991. [3]                 On June 1, 1993, the Minister reassessed Metro-Can for both its 1989 and 1990 taxation years. ... Notices of Objection to the 1993 reassessments were filed by the applicant on August 17, 1993. [4]                 The Minister confirmed the reassessments on June 19, 1995. ... Thus, from the time they were filed until the final reassessment, the appellant did not know what his actual liability was. [15]            In the case at bar, the Notice of Reassessment that was objected to and appealed is dated June 1, 1993. ...