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  [7]                During the 2001 and 2002 tax year, there was no federal tax, interest or penalty assessed for those years against the appellant.  As such, the assessments for the 2001 and 2002 tax years were nil assessments ... )     [9]                There is thus no basis for disturbing the findings of the Tax Court that the appeals for the 2001 and 2002 years should be quashed. [10]            The appeal should be dismissed without costs.       ...

  [2]                At the hearing in the Tax Court of Canada, the appellant conceded that the amount of the indebtedness in issue was $57,573 (the “indebtedness”), which arose out of advances made by the appellant to 609574 BC Limited (“609574 BC”) in 2000 and 2001, and the Crown conceded that the indebtedness had become uncollectible in the appellant’s 2002 taxation year ... As a result of these findings, the Tax Court Judge concluded that the appellant was not entitled to a deduction under paragraph 20(1)(p) of the ITA of the amount of the indebtedness that had become uncollectible in its 2002 taxation year ... Nikolaisen, [2002] 2 S.C.R. 235.) Here, the question is largely factual in nature ...

Facts [3]                In 2002 and 2003, Mr. Berg participated in a so-called charitable donation program where he received inflated tax receipts. ...   [5]                On November 19, 2002, Mr. Berg purchased 68 timeshare units with a fair market value (FMV) of $242,000.   ...   [6]                On December 6, 2002, Mr. Berg transferred the timeshare units to Cheder Chabad which, at all times material to this case, was a registered charity under the Act. ...

It is useful to reproduce these tables (deleting reference to income received from another uncontroversial source): Income as assessed by the Minister   2000 2001 2002 Rental Income     $ 69,523.99 ISTO trades – Cap. Gains       $ 601,135.38   Income as per the Appellant   2000 2001 2002 Rental Income $ 5,052.80 $ 8,460.29 $ 34,707.90 ISTO trades – Bus. ... Nikolaisen, 2002 SCC 33, [2002] 2 S.C.R. 235, at paragraph 30). [18]            In the present case, the errors asserted are errors of law that are reviewed on the correctness standard. ...

Respondent       A-153-07 BETWEEN: HER MAJESTY THE QUEEN Appellant and   TIMOTHY WALLACE Respondent       A-154-07 BETWEEN: HER MAJESTY THE QUEEN Appellant and   JOHN CASSILS Respondent       A-155-07 BETWEEN: HER MAJESTY THE QUEEN Appellant and   MARIA WONG Respondent     A-156-07 BETWEEN: HER MAJESTY THE QUEEN Appellant and   ROBERT GLASS Respondent       A-157-07 BETWEEN: HER MAJESTY THE QUEEN Appellant and   JOHN ZAYTSOFF Respondent       A-158-07 BETWEEN: HER MAJESTY THE QUEEN Appellant and   BRIAN MCGAVIN Respondent       A-159-07 BETWEEN: HER MAJESTY THE QUEEN Appellant and   AEBAG HOLDINGS LTD. ... Canada (C.A.), [2002] 2 F.C. 288, [2001] 4 C.T.C. 82, 2001 D.T.C. 5471. ...   [24]            The first case is Canada v. Canadian Pacific Limited (F.C.A.), [2002] 3 F.C.R. 170.   ...

Nikolaisen, 2002 SCC 33, [2002] 2 S.C.R. 235 (Decor Grates Inc. v. Imperial Manufacturing Group Inc., 2015 FCA 100, [2015] F.C.J. ... DOCKET: A-511-14     STYLE OF CAUSE: AGRACITY LTD v. HER MAJESTY THE QUEEN     PLACE OF HEARING: Toronto, Ontario   DATE OF HEARING: September 30, 2015   REASONS FOR JUDGMENT BY: WEBB J.A.   ... NEAR J.A.   DATED: December 16, 2015   APPEARANCES: Justin Kutyan Thang Trieu   For The Appellant   Pascal Tétrault   For The Respondent   SOLICITORS OF RECORD: KPMG Law LLP Toronto, Ontario   For The Appellant William F. ...

On February 15, 2002, she requested an adjournment on the basis that she had been called for jury duty. ... At the hearing on February 27, 2002, the applicant appeared and again sought an adjournment. It was granted and the matter was "scheduled peremptorily" for hearing on September 30, 2002. [3]                 On September 23, 2002, the respondent requested an adjournment on the basis, this time, that her mother had suffered a stroke and that the applicant's family was moving from their home on the date of the scheduled hearing. ...

Only the reassessments with respect to the 2001, 2002 and 2003 taxation years are at issue ... For the 2001 and 2002 taxation years, the appellants submitted that they had paid annual management fees of $47,000 for the services of Amin Hachem. ...   [7]                In Housen v. Nikolaisen, 2002 SCC 33, [2002] 2 S.C.R. 235, the Supreme Court wrote the following at paragraph 18: The trial judge is better situated to make factual findings owing to his or her extensive exposure to the evidence, the advantage of hearing testimony viva voce, and the judge’s familiarity with the case as a whole.  ...

NOËL J.A.                         TRUDEL J.A.   BETWEEN: WALTER STURZER Appellant and HER MAJESTY THE QUEEN Respondent     REASONS FOR JUDGMENT OF THE COURT (Delivered from the Bench at Montréal, Quebec, on November 16, 2009) NOËL J.A. [1]                This is an appeal from a decision rendered by Bédard J. of the Tax Court of Canada (the Tax Court Judge) wherein he dismissed Walter Sturzer’s (the appellant) appeal for reassessments made by the Minister of National Revenue (the Minister) with respect to his 2000, 2001 and 2002 taxation years ... From 2000 to 2002, he disbursed $1,538,683 for the construction of a residence on this land ...   [5]                The income reported by the appellant for the relevant taxation years was $52,000, $41,000 and $45,000 for the year 2000, 2001 and 2002 taxation years respectively ...

Nikolaisen, 2002 SCC 33, [2002] 2 S.C.R. 235 at para. 36 [Housen]. V. ... Canada (Attorney General), 2002 SCC 62, [2002] 3 S.C.R. 269 at para. 56. [199] The parallel expression in the French version of Regulation 4801(a) does not use the French equivalent of “distribution” — “placement” (see, for example, Loi sur les valeurs mobilières, R.L.R.Q, c. ... Hanson Brandon Barnes Trickett   For The Appellants   Linda Plumpton John Tobin James Gotowiec   For The Appellants   Ifeanyi Nwachuku Tanis Halpape Jeremy Tiger Jason Winter For The Respondent   SOLICITORS OF RECORD: Fillmore Riley LLP Barristers and Solicitors Winnipeg, Manitoba   For The Appellants   Torys LLP Barristers and Solicitors Toronto, Ontario   For The Appellants   Shalene Curtis-Micallef Deputy Attorney General of Canada   For The Respondent     ...