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TCC
Binette v. The Queen, 2006 TCC 73 (Informal Procedure)
(ii) He did not know the other associates of the partnership. (iii) He did not participate in any associates meetings. ... Papion [13] In December 2005, Claude Papion, a computer expert, was mandated by the Respondent to carry out an assessment of the requests regarding the partnership's scientific research activities using the documentation submitted by the partnership and the documentation related to the assessment of admissibility of the partnership's prior research work, carried out by Georges Husson, external scientific reviser who had done work for Revenue Canada. ... This report dated January 17, 2005, was submitted as evidence by the Respondent (Exhibit I-1). ...
FCTD
Hérold v. Canada Revenue Agency, 2011 FC 544
Justice Rennie BETWEEN: NICOLE HÉROLD A.K.A. NORA HÉROLD Applicant and CANADA REVENUE AGENCY (CRA) Respondent REASONS FOR JUDGMENT AND JUDGMENT [1] The applicant seeks judicial review of the decision of the Canadian Human Rights Commission (the Commission), dated May 26, 2010, wherein the Commission decided not to refer the applicant’s complaint under the Canadian Human Rights Act, RSC 1985, c H-6 (the Act) to the Canadian Human Rights Tribunal because it was trivial, frivolous, vexatious or made in bad faith ... [9] The applicant first complained about Mr. Kast in 2005. ... Prupas FOR THE RESPONDENT SOLICITORS OF RECORD: FOR THE APPLICANT Myles J. ...
FCTD
Shaw Estate v. Canada (Attorney General), 2021 FC 576
New Brunswick, [2008] 1 S.C.R. 190, 2008 SCC 9, at para. 51 (" Dunsmuir "). ... Canada (Customs and Revenue Agency), 2005 DTC 5245, 2005 FCA 153, that unreasonableness simpliciter (one of the two deferential standards then applied by the courts) was the standard of review applicable to a decision made under subsection 220(3.1). [32] Issues of procedural fairness are reviewable on the standard of correctness; see the decision in Canada (Citizenship and Immigration) v. ... That test is as follows: [W]hat would an informed person, viewing the matter realistically and practically – and having thought the matter through – conclude. ...
TCC
Johnson v. The Queen, 2022 TCC 31
Minister of National Revenue, 2013 FCA 250; Addison & Leyen Ltd. v. ... The Queen, 2004 FCA 403 (leave to appeal denied 2005 CarswellNat 1110 (S.C.C.)). [5] Ruremesha v. ... The Queen, 2005 TCC 330, at para. 27. [20] 2015 SCC 41. [21] Gratl v. ...
TCC
Burke v. The King, 2022 TCC 158 (Informal Procedure)
Therefore, subsection 152(7) of the Income Tax Act, RSC 1985, c.1, as amended (the “ Act ”) was deployed. ... The receipt covered the precise period, from 2005 when the cash was received until 2019. ... Burke’s house sale upon marriage breakdown in 2005. He said this amount, some $37,000 by the court’s arithmetic, was retained and used when needed. ...
FCA
The Queen v. Macdonald, 2018 FCA 128, aff'd 2020 SCC 6
MacDonald or the respondent) against reassessments issued with respect to his 2004, 2005, 2006 and 2007 taxation years. ... MacDonald became entitled by reason of the business loss claimed for his 2005 taxation year. [19] Notices of objection were filed by Mr. ... Roth For The Respondent SOLICITORS OF RECORD: Nathalie G. Drouin Deputy Attorney General of Canada For The APPELLANT Davies Ward Phillips & Vineberg LLP Toronto, Ontario For The Respondent ...
TCC
Oltcpi Inc. v. M.N.R., 2008 TCC 470
Weisman, Deputy Judge Appearances: Counsel for the Appellant: R. ... Weisman" Weisman D.J. Citation: 2008 TCC 470 Date: 20080825 Dockets: 2007-1674(EI) 2007-1675(CPP) BETWEEN: OLTCPI INC., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent. ... [2] Renu Arora is a Registered Dietician. In July 2005, she responded to OLTCPI’s advertisement on the Dieticians of Canada website, which sought a dietician for Leisureworld’s Lawrence Avenue facility in Toronto. ...
FCTD
Vézina v. Canada (Defence), 2011 FC 79
[14] Although the applicant’s arguments for the conversion of his application for judicial review into an action are not very clear, three reasons emerge from his written and oral submissions: (1) extending the review to 2003 to 2005 and 2008 to 2010, (2) claiming interest under the Civil Code of Québec since the filing of his grievances and (3) adducing evidence by testimony instead of affidavits. ... Invoking the three-year limitation period provided for in the Civil Code of Québec, he submits that the filing of his grievance in 2006 interrupted this period and that he could therefore also claim for 2003 to 2005 should his application be converted into an action. ... I agree with the respondent that conversion into an action cannot relieve the applicant of his failure to have challenged by way of grievance the amount of compensation that he could have received for the years from 2003 to 2005. ...
TCC
9259-9893 Québec Inc. v. The Queen, 2015 TCC 189 (Informal Procedure)
Canada, 2005 FCA 425, [2005] G.S.T.C. 200, the Federal Court of Appeal held that there is a very simple and pragmatic reason as to why the burden is on the taxpayer. ... [Emphasis added.] [21] In Ruest v. The Queen, 1999 CanLII 346 (TCC), the assessments were made using the ‟ net worth ˮ method as the appellant had no bookkeeping or accounting system for his business. ... Pentney Deputy Attorney General of Canada Ottawa, Canada ...
TCC
Kokai-Kuun Estate v. The Queen, 2015 TCC 217
Lyons Appearances: Agent for the Appellant: Anthony Kokai-Kuun Counsel for the Respondent: Karen Truscott JUDGMENT The appeal from the reassessment made under the Income Tax Act for the 2008 taxation year is dismissed. ... According to the loans spreadsheet, by 2005, the outstanding amount due to Zoltan totalled $233,751.79 and that reduced to $218,751.79 as at 2006 after a $15,000 repayment was made to Zoltan. [37] On June 20, 2006, Zoltan sold his 24 shares to Ms. ... the taxpayer elects in his return of income for the year to have the subsection apply. [55] In Harris v The Queen, 2005 TCC 501, 2005 DTC 1179, Sheridan J. found that the failure by Ms. ...