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Bowie” Bowie J.           Citation: 2008 TCC 544 Date: 20080926 Docket: 2007-4329(IT)I BETWEEN: MARILYN JAHNKE, Appellant, and   HER MAJESTY THE QUEEN, Respondent.   ...   [4]           Ibid, at para. 26.   [5]           [1925] S.C.R. 45.   [6]           [1948] S.C.R. 486 ...   [7]           R.S.C. 1985, c. T-2.   [8]           S.O.R./93-12.   [9]           S.S. 1989-90, c. ...

The Queen, 2007 TCC 739 (Informal Procedure)       Docket: 2006-3665(GST)I BETWEEN: MICHEL SCHOEB, Appellant, and   HER MAJESTY THE QUEEN, Respondent. ... Signed at Ottawa, Canada, this 7th day of December 2007.     “Lucie Lamarre” Lamarre, J.   ...   [15]     Accordingly, the appeal is allowed.   Signed at Ottawa, Canada, this 7th day of December 2007.   ...

Cotter" Case Management Judge   FEDERAL COURT SOLICITORS OF RECORD DOCKET: T-163-24   STYLE OF CAUSE: TRINITY GLOBAL SUPPORT FOUNDATION v ATTORNEY GENERAL OF CANADA     MATTER CONSIDERED AT TORONTO, ONTARIO WITHOUT PERSONAL APPEARANCE OF THE PARTIES     judgment and reasons: ASSOCIATE JUDGE JOHN C. COTTER   DATED: February 25, 2025   WRITTEN SUBMISSIONS BY: Duane R. Milot Max H. Shin   For The Applicant   Linsey Rains Mitchell Meraw   For The Respondent   SOLICITORS OF RECORD: MILOT LAW Barristers and Solicitors Toronto, Ontario   For The Applicant   Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Ontario   For The Respondent       ...

  [13]     I quote a few paragraphs from that letter:   [TRANSLATION]               We hereby wish to advise you that we have assessed your case under        An Act to facilitate the payment of support.               ... For the year 2001: ·         Tuition fees of $187. ·         Education amounts of $480. ·         Medical expenses of $470. ·         Eligible donations of $5 ... Signed at Ottawa, Canada, this 18th day of June 2007.       “Louise Lamarre Proulx” Lamarre Proulx J.     ...

costs;   AND UPON reading the material filed and hearing submissions from counsel for the Appellant and counsel for the Respondent;     THIS COURT ORDERS THAT:   1.       ... Factor 6 – Whether the Trial is by Judge or Jury: [47]         This factor is not relevant in Tax Court appeals. ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

  [48]            In my view, these facts suggest a high degree of deference.               ... JUDGMENT               For all these reasons the application is hereby dismissed with costs.       ... Deputy Attorney General of Canada      FOR RESPONDENT             SCHEDULE “A”   EXCLUSION   1. ...

I quote from paragraph 33, where Justice Mainville indicated that: (…) the burden is on the directors to prove that the conditions required to successfully plead such a defence have been met. (…) The directors must thus establish that they exercised the degree of care, diligence and skill required “ to prevent the failure ”. ... Leckie   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

Reasons for Judgment Lamarre Proulx, J.T.C.C. [1] These are appeals concerning the deduction of rental losses for the 1993, 1994 and 1995 taxation years. [2] In making reassessments, the Minister of National Revenue (the "Minister") relied on the facts set out in paragraph 12 of the Reply to the Notice of Appeal (the "Reply") as follows: [TRANSLATION] (a) during the years in issue, the appellant was the owner of the property located at 890, 892 and 894 St-Édouard Street in St-Jude, in the Province of Quebec (hereinafter the "property"); (b) on July 12, 1996, the appellant informed the Minister that the initial purpose in purchasing the property had been to provide his children with living accommodations; (c) the appellant also informed the Minister that he had used advertisements at the "video club" and "word of mouth" in renting his units; (d) for the 1993, 1994 and 1995 taxation years, the appellant reported the following rental income and expenses: Description 1993 1994 1995 Income: $3,150 $3,000 $3,875 Expenses: Taxes $1,556 $1,206 $1,225 Electricity $ 850 $ 883 $ 773 Insurance $ 953 $ 963 $1,516 Interest/mortgage $6,622 $5,902 $6,241 Maintenance/repairs $1,993 $ 134 $1,152 Subtotal $11,974 $ 9,088 $10,907 NET LOSS ($ 8,824) ($6,088) ($ 7,032) (e) the fixed costs alone totalled $9,981 in 1993, $8,954 in 1994 and $9,755 in 1995; (f) the appellant has incurred the following net losses over the past years: Year Net loss 1991 $10,630 1992 $10,002 1993 $ 8,824 1994 $ 6,088 1995 $ 7,032 (g) during the years in issue, 894 St-Édouard Street was used by the appellant, who owned a video club; (h) during the years in issue, the appellant reported a monthly rent for 894 St-Édouard Street of $100, which was far less than fair market value; (i) the Minister's examination of the video club's books showed that the rents referred to in paragraph (h) above were never paid to the appellant; (j) for the 1993 and 1994 taxation years, the appellant gave 890 St-Édouard, St-Jude as his personal address on his income tax returns; (k) during the years in issue, the property was leased by the appellant's children at a price below fair market value; (l) during the years in issue, 892 St-Édouard Street was not rented; (m) consequently, there was no expectation of profit from leasing the property; (n) during the years in issue, the appellant was thus unable to show that the expenses of $8,824 for the 1993 taxation year, $6,088 for the 1994 taxation year and $7,032 for the 1995 taxation year were incurred for the purpose of gaining or producing income from a business or property. [3] The witnesses were the appellant himself and Robert Lévesque. ...

Smith” Smith J.           Citation: 2016 TCC 6 Date: 20160106 Docket: 2014-1385(IT)I BETWEEN: ELLEN LEIBOVICH, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... He was viewed as “ an eligible candidate ”. [15]         J never attended Vanguard. ... Smith DATE OF JUDGMENT: January 6, 2016   APPEARANCES:   Agent for the Appellant: Charles Leibovich     Counsel for the Respondent: Sara Jahanbakhsh   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: William F. ...

The Queen, 2014 TCC 370     Docket: 2012-2894(IT)G BETWEEN: GURCHARANJIT BUDWAL, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Truscott COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada   [1]   $149,054 x 60% = $89,432 for G. ...