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FCTD

Hunter v. Canada Revenue Agency, 2012 FC 1223

Justice Campbell   BETWEEN:   NANCY HUNTER       Applicant   and       CANADA REVENUE AGENCY       Respondent                      REASONS FOR ORDER AND ORDER   [1]                The present Application is a judicial review of a decision of the Canada Revenue Agency (CRA), dated May 30, 2010, in which the Applicant’s request for interest relief pursuant to the taxpayer relief provision of subsection 220(3.1) of the Income Tax Act, RSC 1985 c I (5th Supp) (the Act) was denied. ... The interest had arisen on the Applicant’s account due to tax liability imposed on the Applicant in the course of a tax audit for the 2001 and 2002 tax years ... On the question of CRA delay, the Decision provides as follows: I have reviewed your file, including the reassessment made for 2001 and 2002 and the consideration of your Notices of Objection by Appeals Division. ...
FCTD

3651541 Canada inc. v. Canada (Attorney General), 2007 FC 1255

Friedmann has provided affidavits from his doctors to the effect that his health condition remained poor until the end of 2002. ... Friedmann also affirms that he remained on anti-depressants and other medications throughout 2002 and 2003 ...   [5]                In July 2002, the applicant’s accountant sought extensions of time to file the tax returns of the applicant and its Predecessor Corporations ...
FCTD

Stenger v. Canada (Attorney General), 2019 FC 1561

These are the reports we have on file: —   your application and your questionnaire —   your family doctor’s report dated April 15, 2004 with enclosures including copies of a report from a rheumatologist dated October 20, 1997, copies of reports from a second rheumatologist dated July 19, 2000, November 5, 2001 & April 15, 2002, a copy of a report from a respirologist dated December 19, 2001, clinic chart notes dated January 22, 2001 & February 7, 2001 and copies of reports from family doctors dated February 16, 2001 & December 2, 2002 —   your self-employment questionnaire dated January 20, 2005 and your T4A tax forms from Royal Lepage Noralta real estate for the years 2001, 2002 & 2003 We recognize that you have identified limitations resulting from health problems related to ankylosing spondylitis.   ... We considered the following factors in making the decision. —   According to your respirologist, in December 2001, you appeared well and still had reasonable chest expansion. —   According to your self-employment questionnaire, you reduced your hours of work drastically in 2003, which is well after the end of your qualifying period a CPP disability benefit. —   According to your T4A tax forms, you had self-employment earnings for 2001, 2002 & 2003 and your 2002 earnings were substantially gainful. ... DATED: december 5, 2019   APPEARANCES: James A. Wachowich   For The Applicant   Matthew Vens   For The Respondent   SOLICITORS OF RECORD: Wachowich & Company LLP Barristers and Solicitors Edmonton, Alberta   For The Applicant   Attorney General of Canada Gatineau, Qu ébec For The Respondent     ...
FCTD

Gibson v. Canada, 2004 FC 809

Canada, [2002] F.C,J. No. 517 (T.D.)(QL), aff'd [2002] F.C.J. No. 1396 (C.A.) ... McCARTHY                                      FOR THE APPLICANT Barrister and Solicitor Ottawa, Ontario                                                MORRIS ROSENBERG                                            FOR THE RESPONDENT Deputy Attorney General of Canada Ottawa, Ontario [1] Parts II and III of this Act were repealed by 2002, c. 24, Sched B., s. 26(1), effective January 1, 2004: Limitations Act, 2002, S.O. 2002, c. 24, Sched. B.    Section 45 was in Part III of the former LA. For the purposes of this proceeding, section 45 remains applicable, by virtue of section 24 of the Limitations Act, 2002. ...
FCTD

Canada (Minister of National Revenue) v. Blouin, 2003 FCT 178

"Yvon Pinard"                                                                                                                                                                   Judge                      OTTAWA, ONTARIO February 18, 2002 Certified true translation Suzanne M. ... Tr., LL.L.                                                  FEDERAL COURT OF CANADA                                                               TRIAL DIVISION                             NAMES OF COUNSEL AND SOLICITORS OF RECORD FILE:                                                   T-2119-02 STYLE OF CAUSE:                           INCOME TAX ACT v. ROGER BLOUIN PLACE OF HEARING:                     Québec, Quebec DATE OF HEARING:                       February 13, 2003 REASONS FOR ORDER BY:          Pinard J. ...
FCTD

Jewett v. Canada (Attorney General), 2019 FC 200

Specifically, the Applicant requested the following: 1.   The Cancellation of interest for the 2002 taxation year from January 01, 2006 to May 1, 2008 and March 5, 2013 to October 5, 2016; 2.   ... No agreement to waive any interest that would otherwise accrue on the 2002 and 2003 tax years starting on May 25, 2016. [2]   In this application for judicial review, the Applicant seeks the following relief: 1.   ... MacGregor set out the factors she considered in making her recommendation to grant partial relief, as follows: In coming to my recommendation for granting the applicant partial interest relief, I considered carefully the circumstances of the applicant, and concluded that the applicant was prevented from meeting his payment obligations due to some CRA delay, and in particular:   on May 2, 2008, the applicant served his request for an extension of time to file objections to the Minister’s reassessments for his 2002 and 2003 taxation years;   on August 20, 2008, the applicant served his objections to the Minister’s reassessments for his 2002 and 2003 taxation years;   on February 18, 2009, CRA acknowledged receipt of the applicant’s objections for his 2002 and 2003 taxation years;   on or about October 26, 2009, CRA closed the file for the Applicant’s objections for his 2002 and 2003 taxation years;   in May/June 2010, CRA officers incorrectly advised the applicant, in writing and in a telephone call, that the applicant’s objections for the 2002 and 2003 taxation years remained active and under review; and   on June 24, 2011, the applicant served second objections for his 2002 and 2003 taxation years. [39]   The Applicant received partial relief for interest in respect of the 2002 taxation year, from June 24, 2011 to March 5, 2013. [40]   Pursuant to the second level review of his second request for relief, the Applicant received relief for interest for the 2002 and 2003 taxation years, from May 2, 2008 to June 24, 2011. [41]   The affidavit of Ms. ...
FCTD

Ugro v. Canada (National Revenue), 2009 FC 825

    [6]                The Applicant’s 2002 to 2005 income tax returns were not filed on time. ... The Applicant’s 2002 to 2005 tax returns were not audited prior to being assessed as filed.   ...   [12]            On April 21, 2008, the Applicant’s 2002 to 2005 taxation years were reassessed pursuant to an audit conducted by the Minister. ...
FCTD

Carter-Smith v. Canada (Attorney General), 2006 FC 1175

We issued a formal demand for the tax year 2000 in February of 2002.  ... We have considered the above facts and have determined that the application of the late-filing penalties against the 2000, 2001 and 2002 T1 return was correct.  ... CONCLUSION [25]            For the foregoing reasons, the decision under review will be set aside and the Applicant’s application for relief from penalties and interest imposed in respect of her 2000, 2001 and 2002 taxation years is referred back to the Respondent for reconsideration and re-determination by a different officer ...
FCTD

Laflamme v. Canada (National Revenue), 2010 DTC 5070 [at at 6794], 2008 FC 1403

  [4]           In 2002, a series of catastrophic events occurred. First, the applicant’s husband died suddenly; her mother and father-in-law died the same year. ... After 2002, with no income to live on, the applicant had to find a job, and had to change jobs three times between 2002 and 2005. ...   [31]       In this case, the uncontradicted evidence is that the applicant was the victim of numerous distressing events between 2002 and 2007: her husband died suddenly in 2002, and her mother and father-in-law died the same year. ...
FCTD

Canada (Minister of National Revenue) v. Thériault-Sabourin, 2003 FCT 124

REASONS FOR ORDER LAYDEN-STEVENSON J. [1]                 On December 9, 2002, a jeopardy order was made pursuant to subsection 225.2(2) of the Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.) ... The result was a tax liability of $679,891.65    Mr. Sabourin has filed Notices of Objection with respect to the reassessments and the assessment. [6]                 On April 17, 2002, Léo Sabourin presented a proposal to his creditors under the Bankruptcy and Insolvency Act, R.S.C. 1985, c. ... On October 15, 2002, the respondent entered an agreement of purchase and sale respecting the sale of 1651 Marronier Court. ...

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