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Each filed tax returns for the 2000, 2001 and 2002 taxation years in which they claimed certain deductions.  ... Sylvan Lake Golf & Tennis Club Ltd., [2002] 1 S.C.R. 678, at paragraph 32, the Supreme Court of Canada restated the principle that applies when a party seeks to raise a new issue on appeal.  ... Dawson” J.A.     “I agree       Carolyn Layden-Stevenson J.A.”     “I agree       David Stratas J.A.”     ...

EVANS J.A.                                       PELLETIER J.A.   BETWEEN: TORONTO DISTRICT SCHOOL BOARD Appellant     and   HER MAJESTY THE QUEEN Respondent       Heard at Toronto, Ontario, on November 10, 2009. ... EVANS J.A.                                       PELLETIER J.A.   BETWEEN: TORONTO DISTRICT SCHOOL BOARD Appellant     and   HER MAJESTY THE QUEEN Respondent       REASONS FOR JUDGMENT OF THE COURT (Delivered from the Bench at Toronto, Ontario, on November 10, 2009)   EVANS J.A. [1]                This is an appeal by the Toronto District School Board from a decision by the Tax Court of Canada in which Justice Campbell Miller dismissed the Board’s appeal from the disallowance of its claim for a rebate of the Goods and Services Tax (“GST”) that it had paid from August 2002 to February 2004. ... E-2, and thus subject to the control of the Minister of Education, because it had not discharged its statutory duty of producing a balanced budget for the year 2002. ...

NOËL J.A.                                         RYER J.A.   BETWEEN: HER MAJESTY THE QUEEN Appellant     and       JOSEPH FONTANA Respondent       Heard at Toronto, Ontario, on May 5, 2008. ... Joseph Fontana from a reassessment of his income for 2001 and 2002, that was issued by the Minister of National Revenue (the "Minister") pursuant to the Income Tax Act, R.S.C. 1985, c. 1 (5 th Supp.) ... Schwalm Barrister & Solicitor Windsor, Ontario     FOR THE RESPONDENT     ...

BETWEEN:                                                 ATTORNEY GENERAL OF CANADA                                                                                                                                                        Applicant                                                                                  and                                                     NATIONAL BANK OF CANADA                                                                                                                                                                                                                                        Respondent                                        REASONS FOR JUDGMENT OF THE COURT                         (Delivered from the bench at Montréal, Quebec, on May 29, 2003) LÉTOURNEAU J.A. [1]                 This is an application for judicial review by the Attorney General of Canada of a decision of the Tax Court of Canada dated February 21, 2002. ... Canada (Minister of National Revenue), 2002 FCA 171, dated May 3, 2002, is applicable in this case, and accordingly the application for judicial review must be allowed. ... Messier-Lafleur were benefits paid by the respondent "in respect of such employment", and were therefore insurable earnings. [13]            For these reasons, the application for judicial review will be allowed with costs, the decision of the Tax Court of Canada dated February 21, 2002, will be set aside and the matter will be returned to the Chief Judge of the Tax Court of Canada or to his designate, for a new determination on the basis that the appeal by the respondent must be dismissed with costs.                                                                                                                                        ...

  [24]            In an unrelated transaction that occurred in 2002, Copthorne III was amalgamated with five other corporations owned by the Li family and continued as Copthorne Holdings Ltd., the appellant in this appeal   DECISION OF THE TAX COURT OF CANADA [25]            In the Tax Court of Canada, the issues were whether the Minister properly applied the GAAR and if so, whether the penalty was validly imposed. ... Her Majesty the Queen, 2001 FCA 260, [2002] 2 F.C. 288. In Canada Trustco, the Court adopted the “pre-ordination” test that was laid down by Justice Rothstein in OSFC with respect to the determination of whether there is a series of transactions for the purposes of those provisions. ... Nikolaisen, [2002] 2 S.C.R. 235, 2002 SCC 33).       General Approach to the Application of the GAAR [37]             The requirements that underpin a valid GAAR assessment are summarized in the excerpt from the reasons in Canada Trustco that is reproduced in paragraph 26 of these reasons. ...

Nikolaisen, [2002] 2 S.C.R. 235, Rouleau v. Canada, 2008 FCA 288. Nor is it within our jurisdiction or is it our intention to substitute our own: ibidem ...   [8]                For these reasons, I would dismiss the appeal with costs.     ... Deputy Attorney General of Canada   FOR THE RESPONDENT       ...

NOËL J.A.                                         NADON J.A.   BETWEEN: CONCETA PASSUCCI Appellant and   HER MAJESTY THE QUEEN Respondent           REASONS FOR JUDGMENT NADON J.A. [1]                This is an appeal from a decision of Madam Justice Lucie Lamarre dated July 5, 2006, which dismissed the appellant’s appeal from the Minister’s assessment under the Excise Tax Act for unremitted Goods and Services Tax (“GST”) in the amount of $36,981.14 and for disallowed input tax credits (“ITCs”) in the amount of $849.40, together with interest and penalties for the period of January 1, 1999, to December 31, 2002. [2]                Considering that a substantial portion of the evidence adduced before the Tax Court, including the transcripts of the viva voce evidence, does not form part of the record which is before us, I cannot conclude that the Tax Court Judge made any error which would allow us to intervene ... Nadon” J.A.   “I concur”.             “Alice Desjardins, J.A.”   “I agree.”             ... NOËL J.A.     DATED:                                                                                  April 19, 2007     APPEARANCES:   Mr. ...

Nikolaisen, [2002] 2 S.C.R. 235, 2002 SCC 33. [12]            We are not persuaded that the Tax Court Judge made any such error in his application of the statutory language to the facts, which indicate that the appellants exercised no real control over the cheques ...   [16]            For these reasons, the appeals will be dismissed with costs.   ... DELIVERED FROM THE BENCH BY:                             EVANS J.A.     ...

HASIUK Appellant and   HER MAJESTY THE QUEEN Respondent       Heard at Toronto, Ontario, on October 1, 2008. ... Nikolaisen, [2002] 2 S.C.R. 235 at paragraph 10.)  The record of this case discloses no such error. ... Sharlow” J.A.           FEDERAL COURT OF APPEAL   NAMES OF COUNSEL AND SOLICITORS OF RECORD       DOCKET:                                                                               A-591-07   (APPEAL FROM AN ORDER OF THE HONOURABLE MR. ...

Appellant and HER MAJESTY THE QUEEN Respondent               Heard at Vancouver, British Columbia, on November 1, 2012. ... E-15, for the period March 1, 2002 to February 29, 2004 (2010 TCC 352). ... APPEARANCES:   Earl Babich   FOR THE APPLICANT   Selena Sit   FOR THE RESPONDENT       SOLICITORS OF RECORD:   N/A   FOR THE APPLICANT   Myles J. ...