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DAWSON J.A.                         STRATAS J.A.   BETWEEN: HER MAJESTY THE QUEEN Appellant and   MERCHANT LAW GROUP     Respondent       Heard at Winnipeg, Manitoba, on June 22, 2010. ... Canada, [2002] T.C.J. No. 148 at paragraph 12.   [24]       In the present case the Judge, while referencing liability under contract as being an indicator of an agency relationship, failed to address whether the respondent or its client was liable under the agreements with third-party suppliers to pay the consideration owing under those agreements. ... Casey Churko   FOR THE RESPONDENT       SOLICITORS OF RECORD:   Myles J. ...

Date: 20070912   Dockets: A-50-06 A-174-06   Citation: 2007 FCA 280   CORAM:       RICHARD C.J.                         ... That proceeding is pending and is under case management. [4]                In April and May of 2005, the Minister reassessed the First Three Parties, and also Paul Walsh and Francis Walsh (who will be referred to collectively as the “Other Parties”), for their 2001 and 2002 taxation years. ... Deputy Attorney General of Canada   FOR THE RESPONDENTS       ...

In 2002 time cards were introduced. The appellant would collect its flat rate on the basis of those time cards (reasons, para. 15). ...   [11]            I would dismiss the appeal with costs.   "Marc Noël" J.A.     ... Andrew Rouse FOR THE APPELLANT   Catherine M.G. McIntyre FOR THE RESPONDENT     SOLICITORS OF RECORD:   D. ...

  [8]                A further audit followed in 2003 in relation to the 2001 and 2002 taxation years. ... [Appeal Book, Tab 12-A at p. 8-9]     [10]            At a meeting held in June 2004 with officials of the Foundation to discuss the audit results, a CRA representative requested donor lists for the 2002 and 2003 taxation years. ... Nikolaisen, 2002 SCC 33, [2002] 2 S.C.R. 235 (Housen), the Foundation says that this Court is not entitled to intervene except in the case of a palpable and overriding error, unless it is dealing with an extricable error of law ...

NOËL J.A.                         TRUDEL J.A.   BETWEEN: VALLEY EQUIPMENT LIMITED Appellant and HER MAJESTY THE QUEEN Respondent     REASONS FOR JUDGMENT OF THE COURT (Delivered from the Bench at Fredericton, New Brunswick, on February 20, 2008)   NOËL J.A. [1]                This is an appeal by Valley Equipment Limited (“Valley Equipment”) from a decision of Campbell J. of the Tax Court of Canada (the “Tax Court Judge”), confirming the assessment issued by the Minister of National Revenue (the “Minister”) with respect to its 2002 taxation year on the basis that damages awarded to Valley Equipment as a result of an unlawful cancellation of a Dealer Agreement with John Deere Limited (“John Deere”) were proceeds of disposition of property, subject to a capital gains tax, and did not constitute a non-taxable capital receipt. ...   [31]            The decision of the Tax Court in Ipsco Inc. v. Canada, [2002] T.C.J. ... FOR THE RESPONDENT       ...

Nikolaisen, 2002 SCC 33, [2002] 2 S.C.R. 235. Palpable and overriding error is a high threshold for interference: Benhaim v. ... Sylvan Lake Golf & Tennis Club Ltd., 2002 SCC 19, [2002] 1 S.C.R. 678. ... THE ATTORNEY GENERAL OF CANADA     PLACE OF HEARING: WINNIPEG, MANITOBA   DATE OF HEARING: November 28, 2017   REASONS FOR JUDGMENT BY: STRATAS J.A.   ...

Date: 20051128 Docket: A-454-04 Citation: 2005 FCA 393 CORAM:        DESJARDINS J.A.                         ... Background [3]                Mr. Walker filed his 1998 tax return on April 30, 1999, and received a notice of assessment for that taxation year on May 20, 1999. [4]                According to affidavit evidence filed by a manager of the Canada Revenue Agency, a notice of reassessment for the 1998 tax year was sent by registered mail to the appellant on May 13, 2002, and was returned unclaimed. ... The first he claims he heard of it was when he was contacted in August of 2002 by a collections officer regarding an amount allegedly due for 1998. ...

The revised amounts of the 1991 and 1992 non-capital losses, $25,824,050 and $8,122,335 respectively, were the subject of notices of loss determination dated April 19, 2002. Those loss determinations were appealed to the Tax Court. [33]            On April 18, 2002, the Minister reassessed CCLI for 1989 to acknowledge that the 1997 reassessment was out of time. In that reassessment, the Minister also purported to change the amounts of the 1989 deductions for the 1991 and 1992 non-capital losses, based on the April 19, 2002 loss determinations. ...

BETWEEN:                                        NORMAN JOHN RAYMOND MACKINNON                                                                                                                                                        Appellant                                                                                  and                                                         HER MAJESTY THE QUEEN                                                              IN RIGHT OF CANADA                                                                                                                                                    Respondent                                    Heard at Vancouver, British Columbia on March 24, 2003.                          ... BETWEEN:                                        NORMAN JOHN RAYMOND MACKINNON                                                                                                                                                        Appellant                                                                                  and                                                         HER MAJESTY THE QUEEN                                                              IN RIGHT OF CANADA                                                                                                                                                    Respondent                                                         REASONS FOR JUDGMENT NOËL J.A. [1]                 This is an appeal from a decision of a learned Motions Judge in which he found that the majority of the tax debt pertaining to the Appellant's 1979 through 1982 and 1997 taxation years, had not been extinguished by operation of the Limitation Act R.S.B.C. 1996, c.266. ... Canada, 2002 D.T.C. 6885 (T.D.) (affirmed 2002 D.T.C. 7462) expressly refers to the registration of this certificate as a means of renewing the limitation period (Markevich, paragraph 18). [5]                 It is therefore clear, in light of Markevich that the Appellant's appeal must suffer the same fate as the cross-appeal. ...

Nikolaisen, 2002 SCC 33, [2002] 2 S.C.R. 235), we are not satisfied that the decision of the Tax Court of Canada contains a palpable and overriding error warranting this Court’s intervention. [8]                The first error alleged by Mr.  ... Boros   REPRESENTING HIMSELF   Andrew Miller Paul Klippenstein   FOR THE RESPONDENT HER MAJESTY THE QUEEN   SOLICITORS OF RECORD: William F. Pentney Deputy Attorney General of Canada   FOR THE RESPONDENT HER MAJESTY THE QUEEN     ...