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Appeals heard on April 9 and 10, 2002, at Montréal, Quebec, by the Honourable Judge François Angers Appearances Counsel for the Appellant:                             Daniel Bourgeois Counsel for the Respondent:                         Nathalie Goyette JUDGMENT           The appeals from the assessments made under the Income Tax Act for the 1993, 1994 and 1995 taxation years are dismissed, with costs. Signed at Edmundston, New Brunswick, this 11th day of December 2002. "François Angers" J.T.C.C. ... Signed at Edmundston, New Brunswick, this 11th day of December 2002. "François Angers" J.T.C.C. ...

[OFFICIAL ENGLISH TRANSLATION] REASONS FOR JUDGMENT Tardif J. [1]      This is an appeal from a decision dated December 17, 2002. ... Fradette, and the manager of the appellant 9072-5755 Québec Inc., were not dealing with each other at arm's length. [2]      The parties agreed to have the two matters heard on common evidence. [3]      The Minister of Revenue relied on the following assumptions of fact to explain and justify his determination: [TRANSLATION] (a)         the appellant was incorporated on January 14, 1999; (b)         the appellant carried on business under the firm name "Hôtel Richelieu"; (c)         within the same building, the appellant operated a room rental business (11 rooms); two taverns with capacities of 75 and 90 seats respectively; and 9 video poker machines; (d)         the appellant operated throughout the year; (e)         the appellant hired roughly ten employees; (f)          Roch Cantin was the appellant's sole shareholder; (g)         Roch Cantin is the worker's spouse; (h)         the worker was hired by the appellant as a manager; (i)          according to the worker, her tasks were to show people the rooms, empty the video poker machines and maintain the payroll journal; (j)          the worker had no fixed work schedule; (k)         the worker was paid a gross fixed salary of $350 per week; (l)          the worker's hours were not entered in the appellant's payroll journal; (m)        the appellant's other employees were paid on an hourly basis; (n)         during the period in issue, the worker signed only two room rental cards; (o)         the worker took 15-20 minutes a day to empty the video poker machines; (p)         the worker's tasks were minor in relation to her pay; (q)         before and after the period in issue, the worker continued to empty the video poker machines and make entries in the payroll journal; (r)         before and after the period in issue, the worker rendered services to the appellant for no declared remuneration; (s)         the period during which the worker claims to have worked is not the same as the period during which she actually worked; (t)          on November 13, 2001, the appellant issued a Record of Employment (ROE) to the worker. ... She placed the necessary amounts in it and ensured that all the bank notes were in excellent condition to avoid problems caused by worn notes. [23]     Colossal amounts, all in small-denomination notes and in 25 ¢, 50 ¢, $1 and $2 coins, needed to be accounted for. ...

Peckitt and Jayar; c)         Linkedin profile – years of experience and his many connections; d)        Referral letters; e)         Power Point presentations to potential clients; f)          Sample of referral agreement; g)        Consulting engagement letter; h)        Automobile log; i)          Sale invoices from Mr. ... The total gross revenue earned and net loss incurred by Jayar for its taxation years ending September 30, 2009, September 30, 2010, September 30, 2011 September 30, 2012 and September 30, 2013 were as follows:   Gross Revenue Net Loss 2009 130,227 (26,228) 2010 9,558 (3,136) 2011 7,784 (12,014) 2012 3,555 (294) 2013 74,458 (9,716) [10]         For the same fiscal periods, Jayar paid the appellant the following consulting fees:           2009 = $ 31,850           2010 = $ 0           2011 = $ 0           2012 = $ 0           2013 = $ 23,500 [11]         According to Mr. ... No. 1218 (Federal Court of Appeal)). [27]         In Stewart v. The Queen, [2002] 2 S.C.R. 645, the Supreme Court of Canada has recommended a two-stage approach with respect to the existence of a source of income. ...

Jarvis, [2002] 3 S.C.R. 757, 2002 SCC 73, the Supreme Court of Canada explained the responsibilities and duties of taxpayers as well as some of the measures contained in the Act that are designed to encourage compliance: 49        Every person resident in Canada during a given taxation year is obligated to pay tax on his or her taxable income, as computed under rules prescribed by the Act … The process of tax collection relies primarily upon taxpayer self-assessment and self-reporting: taxpayers are obliged to estimate their annual income tax payable (s. 151), and to disclose this estimate to the CCRA in the income return that they are required to file (s. 150(1)). … 50        While voluntary compliance and self-assessment comprise the essence of the ITA ’s regulatory structure, the tax system is equipped with “persuasive inducements to encourage taxpayers to disclose their income” … For example, in promotion of the scheme’s self-reporting aspect, s. 162 of the ITA creates monetary penalties for persons who fail to file their income returns.  ... Masse, Deputy Judge DATE OF JUDGMENT: October 6, 2016   APPEARANCES:     Counsel for the Appellant: Archie B. Palinka   Counsel for the Respondent: H. Annette Evans   COUNSEL OF RECORD:     For the Appellant: Archie B. ...

Bonner" Bonner, J.         Citation: 2003TCC565 Date: 20030814 Docket: 2003-117(CPP)   BETWEEN: DIANNE STOJAK, Appellant, and   THE MINISTER OF NATIONAL REVENUE, Respondent.       REASONS FOR JUDGMENT     Bonner, J.   [1]      Faxit Communications Inc. (Faxit) appealed under s. 27.1 [1] of the Canada Pension Plan to the Minister of National Revenue (the "Minister") from an assessment made on the basis that Dianne Stojak was employed by Faxit under a contract of service during 2000, 2001 and 2002. ...

Webb” Webb J.           Citation: 2007TCC651 Date: 20071024 Docket: 2006-3283(GST)I BETWEEN: FLEMING SCHOOL OF DANCE LIMITED, Appellant, and   HER MAJESTY THE QUEEN, Respondent.     ... The Appellant started teaching 3 year olds in 2002. The graduating level for the Appellant was when students would be leaving high school at age 18. ...   [32]     Therefore the appeal is allowed, without costs, and the assessment is vacated.          ...

This is analogous to the appellant's situation in seeking to earn larger bonuses. [33]         Similarly, in Pitzel v Canada, [2002] 2 CTC 2949, paragraphs 8(1)(f) and 8(1)(h) and subsection 8(2) were under consideration. ...   [13]           Except for section 67.1.   [14]          Exhibit R-7. ...   [15]          Exhibit R-7.   [16]          Agreement – Clauses B.1. and B.2 ...

[OFFICIAL ENGLISH TRANSLATION] Appeal heard on December 9, 2002 and March 24, 2003 at Québec, Quebec Before: The Honourable Judge Alain Tardif Appearances: Counsel for the Appellant: Jocelyn Vézina Counsel for the Respondent: Dominique Gallant____________________________________________________________________ JUDGMENT           The appeal from the assessments made under the Income Tax Act for the 1999 taxation year is allowed and the assessment is referred back to the Minister for reconsideration and on the basis that the fair market value at the time of transfer, April 17, 1996, was $115,000, with costs to the respondent, in accordance with the attached Reasons for Judgment. ... (e)         On April 16, 1999, the debt was made up of the following: Taxation year 1995 1996 Total Taxes $1,386.44 $56,577.22 $57,963.55 Interest $    356.19 $12,930.19 $13,286.38 Penalties $             0 $ 27,846.62 $ 27,846.62 Total $ 1,742.52 $ 97,354.03 $ 99,096.55 (f)          According to deed 184256 recorded at the Baie Comeau land registry office, the property was transferred in exchange for $83,921,94; (g)         The fair market value of the property on April 17, 1996 was at least $118,300. [4]      To support and prove the FMV, the Respondent called on an expert witness in her employ, Mr. ... Laberge. [23]     There is no doubt, however, that the burden of proof is not on the Respondent, but on the Appellant. [24]     Since Johnston v. ...

Signed at Ottawa, Ontario, this 7th day of November 2014.   “Gaston Jorré” Jorré J.     ... “Gaston Jorré” Jorré J.       Translation certified true on this 13th day of March 2015     François Brunet, Revisor   CITATION: 2014 TCC 333 COURT FILE NOS.: 2011-1939(IT)G 2011-2338(IT)G STYLE OF CAUSE: LES PRODUCTIONS SKY HIGH COURAGE INC., FIDUCIE FAMILIALE SAMSON, v. ... The Queen, 2002 CanLII 809 (TCC), at paragraphs 38 to 42. I note that the respondent has not alleged prejudice. ...

The CRA auditor indicated he was not provided with sufficient information from Christenson Developments Ltd. to break down the costs between the two projects. [12]     LionsVillage introduced at trial the City of Edmonton's Annual Realty Assessment and Taxation Notice for 2002 for the Castledowns complex. [3] It indicated an assessment amount for that complex of $4,424,000. ... buyer and seller are typically motivated;             2.          both parties are well informed or well advised; and acting in what they consider their best interest;             3.          ... Miller DATE OF JUDGMENT:                     December 8, 2006 APPEARANCES: Counsel for the Appellant: Gordon Beck Counsel for the Respondent: Leslie Akst COUNSEL OF RECORD:        For the Appellant:                           Name:                       Gordon Beck                             Firm:                      Fieled LLP        For the Respondent:                     John H. ...