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According to the Minister's computations, the qualified ITC amount for the 1996 taxation year was increased to the following, as set out in Annex B herein enclosed and forming an integral part thereof: ITC for the Year R & D Expenditures                        $2,995.00 Qualified Property                    $490,677.00                    $493,672.00 52.        ... Canada, [2002] T.C.J. No. 168 (Q.L.), at paragraphs 20 to 22: 20         Counsel for the appellant raised the issue of the calculation of depreciation in which periods prior to the normal assessment period were considered. ... "Louise Lamarre Proulx"          Lamarre Proulx J. ...

Bocock Appearances: For the Appellant: The Appellant himself Counsel for the Respondent: Jack Warren   AMENDMENT TO REASONS FOR JUDGMENT           Upon the Court finding typographical errors in certain paragraphs of the Reasons for Judgment issued February 6, 2015, the following paragraphs are amended as follows:             In the first line of paragraph [5], the word “the” is deleted;             In the second line of paragraph [6], the word “the” is deleted;             In the fifth line of paragraph [12], the period after “ … March 2 …” is deleted and replaced with a comma;             In the first line of subparagraph (b) of paragraph [22], the word “the” is deleted; and             In paragraph [39], the word “Respondents” is replaced with “Respondent”.             ... Somerville. [4]              On July 25, 2002, Ms. Somerville purchased the Howe Island Property, again solely in her name, with the intention that the Howe Island Property would be a retirement property. [5]              From 2004 to 2006, Mr.  ... Loates; (b)        Mr. Loates would have “no claim” on the Cochrane Property; (c)         Ms.  ...

[OFFICIAL ENGLISH TRANSLATION] REASONS FOR JUDGMENT Somers, D.J.T.C.C. [1]      This appeal was heard at Montréal, Quebec, on February 26, 2003. [2]      The appellant institutes an appeal from the decision by the Minister of National Revenue (the "Minister") according to which the employment held with Assen International, the payer, during the period in issue, from May 5 to October 4, 2001, was not insurable on the ground that there was no employer-employee relationship between him and the payer. [3]      Subsection 5(1) of the Employment Insurance Act (the " Act ") reads in part as follows:             5.(1) Subject to subsection (2), insurable employment is (a)    employment in Canada by one or more employers, under any express or implied contract of service or apprenticeship, written or oral, whether the earnings of the employed person are received from the employer or some other person and whether the earnings are calculated by time or by the piece, or partly by time and partly by the piece, or otherwise; [...] [4]      The burden of proof is on the appellant. ... Starting in January 2001, he received cheques from the payer of varying amounts, that is $200, $500, $300, $900 and $1,050. [17]     The appellant admitted that the clients whose names appear at pages 8 and 9 of a letter dated June 26, 2002, that he had sent to Human Resources Development Canada were not those of the payer and added that, as a salesman, he had had a right to contact clients. [18]     The appellant admitted that he went to Orlando, Florida at the payer's expense from October 15 to 20, 2001, that is after the period in issue. [19]     Richard Blouin, a witness for the appellant party, said that he had made deliveries to the payer's place of business during 2001 and that he had seen the appellant there on at least 13 occasions. ... ". [33]     In 671122 Ontario Ltd. v. Sagaz Industries Canada Inc., [2001] S.C.J. ...

Paragraphs 1 through 6 state the following:                    FACTS 1.          ... Section 171 states: 171. (1) Disposal of appeal- The Tax Court of Canada may dispose of an appeal by (a)         dismissing it; or (b)         allowing it and             (i)          vacating the assessment,             (ii)         varying the assessment, or (iii)        referring the assessment back to the Minister for reconsideration and reassessment. [15]     Judge Bell, in the case of Thomas Craig Moffat v. ... Canada, [2002] T.C.J. No. 384 which permitted a summary judgment application in this Court, fell somewhere within the application of these rules. ...

Issues [4]   The Minister reassessed the Appellant’s 2012 taxation year as follows: a) to include unreported income of $27,497; and b) levy a penalty under subsection 163(1) for repeated failure to report income. [5]   The unreported income amount consists of the following: Received from Amount Details Homelife Gold Pacific Realty Inc. $27,236 T4A – Other income RBC $US Money Market Fund $25 T3 – Other income RBC Select Very Conservative Portfolio $102 T3 – Other income RBC Select Very Conservative Portfolio $42 T3 – Net capital gains RBC Select Very Conservative Portfolio $49 T3 – Dividend income RBC Select Very Conservative Portfolio $43 T3 – Interest income TOTAL $27,497   [Reply to the notice of appeal at paragraph 5] [6]   The subsection 163(1) penalty has been levied against the total amount of unreported income, i.e. $27,497. ... Thejo at paragraph 12]. [31]   In Stewart v. Canada, 2002 SCC 46 at paragraph 50, the Supreme Court of Canada described and set out the following two-part test for determining whether a taxpayer has a source of income for the purposes of section 9: [50]   It is clear that in order to apply s. 9, the taxpayer must first determine whether he or she has a source of either business or property income. ... Drouin Deputy Attorney General of Canada Ottawa, Canada   ...

Signed at Ottawa, Canada, this 19 th day of September 2012.   “F.J. Pizzitelli” Pizzitelli J.             Citation : 2012 TCC 327 Date : 20120919 Docket: 2008-2808(IT)G   BETWEEN:   REYNOLD DICKIE, Appellant, and   HER MAJESTY THE QUEEN, Respondent.     ... Maple Leaf Meats Inc., 2002 FCA 417, [2003] 2 F.C. 451, and Zeller Estate v. ...

._______________________________________________________________ Appeal heard on October 11, 2002 at Vancouver, British Columbia Before: The Honourable Judge R.D. ... APPELLANT'S SUBMISSIONS: [28]     Appellant referred to Larry Decaire & Dorrin Diesel dba A-OK Construction v. ... The Queen PLACE OF HEARING Vancouver, British Columbia DATE OF HEARING October 11, 2002 REASONS FOR JUDGMENT BY: The Honourable Judge R.D. ...

Webb” Webb J.           Citation: 2008TCC342 Date: 20080610 Docket: 2006-2954(GST)I BETWEEN:   PERFECTION DAIRY GROUP LIMITED, Appellant, and   HER MAJESTY THE QUEEN, Respondent.       ...   [20]     In BJ Services Company Canada v. The Queen, [2002] G.S.T.C. 124, 2003 G.T.C. 513, Justice C. ... Frappier   COUNSEL OF RECORD:          For the Appellant:                             Name:                      Bruce S. ...

Counsel stated that fulfilling domestic obligations does not have a fair market value and cannot be regarded as consideration to reduce a section 160 assessment: Raphael v The Queen, 2002 FCA 23. ... the Spouse is an optometrist;   4.            the Spouse billed the Ontario Health Insurance Plan (“OHIP”) and received payments for his services from OHIP;   5.            ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

Estimate of Value By:          Respondent              Appellant ·         Cost Approach $8,350,000 $8,315,000 ·         Income Approach $6,950,000 $7,050,000 ·         Direct Comparison Approach $7,280,000 $6,970,000 Final Estimate of Fair Market Value $7,350,000 $7,050,000 Valuation of Land $675,000 $645,000 [5]      Mr. ... At no time in 2000, 2001 or 2002 did the Appellant file a return self-assessing in accordance with section 191 of the Excise Tax Act. ... Beck                    Firm:                                Field LLP        For the Respondent:                     John H. ...