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From 1986 to 1991 the appellant reported the following income, expenses and loss from the business of Feldgajer & Feldgajer Consultants: TAXATION GROSS NET INCOME (LOSS) INCOME EXPENSES YEAR 1986 0 $3,448.86 ($3,448.86) 1987 $ 289.57 $1,821.70 ($1,532.13) 1988 $6,349.72 $14,602.23 ($7,034.98) 1989 $ 10.21 $16,101.19 ($14,353.09) 1990 $ 239.91 $18,210.99 ($17,992.86) 1991 $8,048.12 $ 5,787.56 $ 2,260.56 It should be noted that the only large item of income in the years under appeal was about $6,000 which was earned from a contract with ADI Electronics Corporation. ... I think that the business commenced when Mr, Feldgajer formed Feldgajer & Feldgajer Consultants. ... Canada), [1994] 2 C.T.C. 2021, 94 D.T.C. 1947 (T.C.C.) at page 2025 (D.T.C. 1949); see also Griffin, Exp. ...

Civil Code of Québec, CQLR, c CCQ-1991 BOOK FOUR – PROPERTY TITLE TWO – OWNERSHIP CHAPTER I – NATURE AND EXTENT OF THE RIGHT OF OWNERSHIP 947. ... BOOK FIVE – OBLIGATIONS TITLE ONE – OBLIGATIONS IN GENERAL CHAPTER II – CONTRACTS DIVISION IV – NTERPRETATION OF CONTRACTS 1425. ... TITLE TWO – NOMINATE CONTRACTS CHAPTER XII – LOAN DIVISION I – NATURE AND KINDS OF LOANS 2312. ...

Before: The Honourable Justice François Angers   Appearances:   Counsel for the Appellant:   R. ...       « François Angers » Angers J.       Citation: 2007TCC658 Date: 20071116 Docket: 2006-2147(IT)G BETWEEN:   BERNICE MACKINNON, Appellant, and   HER MAJESTY THE QUEEN, Respondent.     ... Canada, [1999] 1 C.T.C. 2025 (T.C.C.).   [53] The fact is that in the history of tax jurisprudence in Canada, involving dozens of cases that consider the statutory definition of “property”, there is not a single case in which the word “property” has been held to include a right that is not or does not entail an exclusive and legally enforceable claim. ...

The issue in determining whether to impose a penalty is whether the appellant has ”... knowingly or under circumstances amounting to gross negligence... has made or has participated in, assented to or acquiesced in the making of a false statement or omission in a return... ”. ... Canada, [1994] 1 C.T.C. 2025, 94 D.T.C. 1009, the appellant forwarded accurate records to his accountant who neglected to include income of over $180,000 in the 1986 taxation year. ...

Fees $8,252.68 Disbursements $1,281.35 GST $ 653.00 Total $9,534.03 I anticipate that work involved in the preparation for trial and attendance at trial will amount to about 50 hours. ... For February 1, 1996, the following item appears in the lawyer's account: T/C" – (which normally is telephone call)-- "from Beth Beattie, husband's counsel; brief review of conditions and amendments of Minutes. ... The Queen, [1999] 1 C.T.C. 2025, my colleague Bonner J. was faced with circumstances similar to this appeal. ...

Réal Bédard in a construction business under the business name Bédard & Sini. ... Sini invested in a number of properties, which we have set out in the following table; Taxation Address Builder Kind of building year Year of sale 1670 Tricentenaire Bédard et 16 units, 1965 not sold Montreal Sini Enrg 4 / rooms each 38 and 40 Cartier Construction 4 / room units 975 not sold 38 and 40 Cartier Laval Mézières Laval 360 De Construction 8 units, 1978 1983 Noirmoutier Mézières 5 /2 rooms each Laval 535 Ampère Construction 8 units, 1979 1981 Laval Mézières 5 / rooms each 2025 Sherbrooke? ... 4 / room units 1981 Montreal? The record does not indicate the name of the builder. ...

., Appellant, and HIS MAJESTY THE KING, Respondent;   Docket: 2003-3382(GST)G AND BETWEEN: 506913 N.B. ... Bocock Bocock J.   Citation: 2024 TCC 136 Date: 20241024 Docket: 2003-3383(GST)G BETWEEN: CAMBRIDGE LEASING LTD., Appellant, and HIS MAJESTY THE KING, Respondent;   Docket: 2003-3382(GST)G AND BETWEEN: 506913 N.B. ... Bocock DATE OF ORDER: October 24, 2024 APPEARANCES:   Counsel for the Appellant: Scott Ellsworth Counsel for the Respondent: Khalid Tariq   COUNSEL OF RECORD: For the Appellant: Name: Scott Ellsworth   Firm: Ellsworth Johnson Michaud For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Canada     [1] Bekesinski v R, 2014 TCC 35, para 28. [2] Logix Data Products Inc. v R., 2021 TCC 36, para 17; see also: Gerbro Holdings Co. v R., 2016 TCC 173, para 141 and Grimes v R., 2016 TCC 280, para 160. [3] White Burgess, supra, para 23. [4] R. v Arp, [1998] 3 S.C.R. 339 (SCC), para 38. [5] Mohan, [1994] 2 S.C.R. 9, para 26. [6] Mohan, supra, para 28. [7] Mohan, supra, para 27. [8] White Burgess, para 15. [9] White Burgess, para 32. ...

This decision has also been examined by other judges of this Court, for example, Judge Dussault in Samson & Frères Ltée v. ... In finding that the business had commenced, Bowman J. stated in his reasons, at page 2025 (D.T.C. 1949): In determining when a business has commenced, it is not realistic to fix the time either at the moment when money starts being earned from the trading or manufacturing operation or the provision of services or, at the other extreme, when the intention to start the business is first formed. ...

Ploughman as the canvasser for the particular applicant; [43]                             ii.                ... Sommerfeldt DATE OF AMENDED JUDGMENT: May 10, 2017   APPEARANCES:   For the Appellant: The Appellant himself Counsel for the Respondent: André LeBlanc   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: William F. ... At the hearing, the Crown indicated that the amount of the penalty was calculated by reference to 135 Donors and their respective official receipts; see Transcript, February 10, 2016, page 127, lines 21-22. [26]          See subsection 163(3) of the ITA. [27]          See The Queen v Taylor [1984] CTC 436, 84 DTC 6459 (FCTD); Johnson v The Queen, [1994] 1 CTC 2025, 94 DTC 1009 (TCC); and Pompa v The Queen, [1995] 1 CTC 466, 94 DTC 6630 (FCA). [28]          Transcript, February 10, 2016, page 140, lines 11-13; February 11, 2016, page 13, line 24 to page 14, line 4. [29]          Guindon (TCC), supra note 2, ¶111. ...

.: — Issue The issue in this appeal is whether the Appellant is subject to a penalty levied under subsection 163(2) of the Income Tax Act (“Act”) for his 1990, 1991 and 1992 taxation years. ... Canada) [1994] 1 C.T.C. 2025, 94 D.T.C. 1009, at page 2027 (D.T.C. 1010) Beaubier J., with respect to subsection 163(3) said, To establish facts in Court is to prove those facts, not merely to assume them. ...