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In finding that the taxpayer was later estopped from amending his pleadings to allege that he had resigned on January 24, 1985, Rip J. stated (pp. 932-933): "... ...

The Queen, 2006 DTC 3548, 2006 TCC 480-- summary under Subsection 227.1(1) Summary Under Tax Topics- Income Tax Act- Section 227.1- Subsection 227.1(1) Before finding that the taxpayer was a de facto director of a corporation that had never been organized on the basis that the taxpayer along with the other major shareholder were the directing minds of the corporation, Paris J. stated (at pp. 3551): "... where a corporation operates without having been properly organized and the only director of record plays no part in running the corporation, those persons who take it upon themselves to direct the affairs of the company may be held to be de facto directors, whether or not they have explicitly represented themselves as directors to any third party. ...

Stormwell (1989), 53 DLR (4th) 435 (BCCA) that "... 'the legislature should not be presumed to have enacted a statute that treats those it affects, or some of them, not just adversely, but unfairly, with respect to acts they have undertaken in the past'... ...

See detailed summary under ETA – s. 153(1). ...

The registrant's business usage was only 54%, which was clearly not " all or substantially all" of the use of the vehicle. ...

MNR, 92 DTC 2019, [1992] 2 CTC 2376 (TCC)-- summary under Subparagraph 20(1)(p)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(p)- Subparagraph 20(1)(p)(i) disposition before year end Before going on to find that a loss realized by a shareholder of a corporation on a disposition part-way through the year to another shareholder of accounts receivable owing to it by the corporation was deductible by it under section 9, Kempo J. stated (p. 2026): "... there is no logic driving paragraph 20(1)(p) to mean that a loss on a bad debt is deductible as a business loss only if it is held to the creditor's year-end but is not deductible as a business loss if it was sold during the year in an arm's length transaction for some consideration.... ...

. … I am satisfied that the disclosure of the Macleod Dixon Memorandum does not bring the tax advice received by the Appellant into issue. ...

MNR, 91 DTC 1020, [1991] 2 CTC 2268 (TCC), rev'd 93 DTC 5467 (FCTD)-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) In vacating an assessment of the taxpayer pursuant to s. 227.1 of the Act and corresponding provisions of the Income Tax Act (Ontario), the Unemployment Insurance Act (Canada) and the Canada Pension Plan Act which informed the taxpayer of the aggregate sum assessed under those statutes without giving a breakdown, Rip TCJ. stated (p. 1027): "... in enacting section 152 of the Act, Parliament required the notice of assessment to inform the person to whom it is sent of the amount of the tax the Minister has assessed under authority of that statute.... ...

I cannot view section 261 … as contemplating a rebate on an error caused by the author's own inattention and carelessness. ...

The Queen, 2016 TCC 73 (Informal Procedure)-- summary under Subsection 152(1.6) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1.6) receipt of notice of redetermination of loss by limited partner not relevant After finding that the presumption in s. 244(20), that notice to the general partner of an LP is notice to all the partners, is conclusive rather than rebuttable, so that a limited partner would not have succeeded even were she able to establish that she had not received notices of determination and redetermination of loss which had been received by the GP, Lafleur J went on to find that even if the s. 244(2) presumption were rebuttable, “the language of subsection 152(1.6) of the Act is clear – whether one or more limited partners have received the notice of determination or not is not relevant for the validity of a notice of determination issued in accordance with subsection 152(1.4) of the Act.” ...