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The Queen, 2010 DTC 1206 [at at 3541], 2010 TCC 310-- summary under Subsection 163(2) Summary Under Tax Topics- Income Tax Act- Section 163- Subsection 163(2) sloppy bookkeeping ≠ gross negligence In finding that the portion of penalties assessed against the taxpayer that were based on related company expenses should be reversed, Woods, J. stated (at para. 42) that: It is quite possible that these errors were a matter of sloppy bookkeeping. ...

., docket A-663-99 (FCA)-- summary under Subsection 225(1) Summary Under Tax Topics- Excise Tax Act- Section 225- Subsection 225(1) In finding that the respondent was responsible for remitting any GST it had collected with respect to its exempt supply of full-time vocational training, Sharlow J.A. stated: "... a taxpayer who has in fact collected GST, whether for services that are taxable or for services that are later determined to be exempt supplies, must remit those amounts as liable to be assessed if they are not remitted. ...

Canada, 2015 FCA 94, aff'g 2014 DTC 1059 [at 2959], 2014 TCC 33-- summary under Ordinary Meaning Summary Under Tax Topics- Statutory Interpretation- Ordinary Meaning no relief for "harsh" (timing difference) consequences In rejecting a submission based on the harshness of s. 34.1 in the taxpayer's circumstances, Woods J noted that the allegedly harsh effect reversed in the following year – and in any event "it is well established that this Court cannot grant relief on grounds only that the result is harsh: Lans v The Queen, 2011 FCA 290. ...

MNR, 91 DTC 1265, [1991] 2 CTC 2442 (TCC)-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) In dealing with a submission that a Revenue Canada official had given the taxpayer some assurance that the taxpayer would not be assessed under s. 227.1, Mogan J. stated (p. 1270): "... ...

BCN Ltée, 79 DTC 5068, [1979] CTC 71, [1979] 1 S.C.R. 865-- summary under Disposition of Property Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Disposition of Property disposition by virtue of merger of leasehold interest and freehold The verb "to dispose" (which should receive the same meaning as the expressions "disposition", "proceeds of disposition" and " disposed of") should be given the broadest possible meaning, and encompasses the idea of destruction or extinguishment. ...

., 97 DTC 55, [1997] 2 CTC 2184 (TCC), briefly aff'd on procedural grounds 2000 DTC 6060 (FCA)-- summary under Subsection 163(2) Summary Under Tax Topics- Income Tax Act- Section 163- Subsection 163(2) In finding that even if (contrary to her actual finding) that amounts received for non-compete covenants by the taxpayer were taxable, penalties would not have been applicable, Lamarre TCJ. stated (at p. 72): "... considering all the different positions taken by the Minister to try to justify his own assessments, I do not see how we can attribute to the appellants a degree of negligence... when especially they have obtained professional advice that the NCA payments were not taxable. ...

The Queen, 96 DTC 6040 (FCA)-- summary under Exempt Receipts/Business Summary Under Tax Topics- Income Tax Act- Section 9- Exempt Receipts/Business In affirming the finding of the Toronto judge that a "gift" received by a practising solicitor in order induce him to act in connection with a Florida real estate project was income, Marceau J.A. stated (at p. 6041): "... ...

The Queen, 96 DTC 6040 (FCA)-- summary under Expense Reimbursement Summary Under Tax Topics- Income Tax Act- Section 9- Expense Reimbursement gift rceeived in course of business In affirming the finding of the Toronto judge that a "gift" received by a practising solicitor in order induce him to act in connection with a Florida real estate project was income, Marceau J.A. stated (at p. 6041): "... ...

The Queen, 2014 DTC 1108 [at at 3229], 2014 TCC 102 (Informal Procedure)-- summary under Pension Income Summary Under Tax Topics- Income Tax Act- Section 118- Subsection 118(7)- Pension Income periodic discretionary withdrawals ≠ periodic amount The taxpayer had discretion as to when and in what amount to withdraw from her RRSP. ...

The Queen, 2014 DTC 1108 [at at 3229], 2014 TCC 102 (Informal Procedure)-- summary under Annuity Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Annuity periodic discretionary withdrawals ≠ periodic amount The taxpayer had discretion as to when and in what amount to withdraw from her RRSP. ...