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TCC

Gibson v. The Queen, docket 1999-4728-IT-I (Informal Procedure)

There were three components of the medical expenses:                                 Whirlpool Spa                                       $8,761.49                                 Travel Costs                                                          4,677.75                                 Miscellaneous                                       1,657.82                                 Total                                                        $15,097.06 By notice of reassessment dated November 1, 1999, the Minister of National Revenue allowed only the following amounts as medical expenses:                                 Travel Costs                                                          $5,147                                 Miscellaneous                                       1,657                                 Total                                                                        $6,804 The Appellant has appealed from that reassessment claiming that the cost of her whirlpool spa ($8,761) is a medical expense or, alternatively, that the cost of installing the whirlpool spa is a medical expense. ... (l.2)          for reasonable expenses relating to renovations or alterations to a dwelling of the patient who lacks normal physical development or has a severe and prolonged mobility impairment, to enable the patient to gain access to, or to be mobile or functional within, the dwelling; (m)           for any device or equipment for use by the patient that (i)             is of a prescribed kind, (ii)            is prescribed by a medical practitioner, (iii)           is not described in any other paragraph of this subsection, and (iv)           meets such conditions as may be prescribed as to its use or the reason for its acquisition; Having regard to any device or equipment "of a prescribed kind" within the meaning of paragraph (m), section 5700 of the Income Tax Regulations contains a list of what is described in the following words: 5700         For the purposes of paragraph 118.2(2)(m) of the Act, a device or equipment is prescribed if it is a                 (a)           ... ... Vantyghem's appeal was allowed. [10]          In Clark v. The Queen, [1994] 4 C.T.C. 2005, Judge Rowe dismissed the appeal of a wife who attempted to deduct as a medical expense the cost of purchasing and installing a hot tub which was prescribed by her husband's arthritis specialist. ...
TCC

Lamoureux v. The Queen, 2016 TCC 47 (Informal Procedure)

He also bought, repaired and rented out real estate rental properties. [4]              The Appellant filed his Goods and Services Tax (“GST”) return for the 2003 Reporting Period on April 4, 2005. ... Miller J.   CITATION: 2016TCC47 COURT FILE NO.: 2015-3412(GST)I STYLE OF CAUSE: TODD LAMOUREUX AND HER MAJESTY THE QUEEN PLACE OF HEARING: Edmonton, Alberta DATE OF HEARING: February 15, 2016 REASONS FOR JUDGMENT BY: The Honourable Justice Valerie Miller DATE OF JUDGMENT: February 22, 2016   APPEARANCES:   For the Appellant: The Appellant himself Counsel for the Respondent: Gergely Hegedus   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada     ...
FCA

Canada (Attorney General) v. Bellil, 2017 FCA 104

ABBES BELLIL     PLACE OF HEARING: MONTREAL, QUEBEC   DATE OF HEARING: MAY 16, 2017   REASONS FOR JUDGMENT BY: DE MONTIGNY J.A.   ... DATED: MAY 17, 2017   APPEARANCES: Carole Vary   FOR THE APPLICANT   Jean-Guy Ouellet   FOR THE RESPONDENT   SOLICITORS OF RECORD: William F. Pentney Deputy Attorney General of Canada Ottawa, Ontario   FOR THE APPLICANT   OUELLET, NADON ET ASSOCIÉES Montreal, Quebec   FOR THE RESPONDENT     ...
FCTD

Tran v. Canada Revenue Agency, 2011 FC 1010

Justice Lemieux BETWEEN:     DUNG TRAN       Applicant   and     CANADA REVENUE AGENCY       Respondent           REASONS FOR JUDGMENT AND JUDGMENT   I.          ...   [47]            Since 2005, he has been the manager of the Large Business Audit Division, the Aggressive Tax Planning Division and the International Audit Division ... DATED:                                              August 19, 2011       APPEARANCES:   Laval Dallaire (for all three files)   FOR THE APPLICANT   Talitha Nabbali (for all three files)   FOR THE RESPONDENT   SOLICITORS OF RECORD:   Gagné Letarte SENCRL Québec, Quebec FOR THE APPLICANT     Myles J. ...
TCC

M R Martin Construction Inc. v. M.N.R., 2006 TCC 196

She was also thinking about returning to school which she did several months later in January 2005. ... (i)          employment if the employer and employee are not dealing with each other at arm's length.... 5(3)    For the purposes of paragraph (2)(i),...           ... M.N.R., [2005] T.C.J. No. 266, adequately review the history and current state of the law in respect to appeals arising pursuant to paragraph 5(3)(b). ...
TCC

Devon Canada Corporation v. The Queen, 2018 TCC 170

The Queen, 2018 TCC 170       Dockets: 2013-1066(IT)G 2013-1327(IT)G BETWEEN: DEVON CANADA CORPORATION, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Drouin Deputy Attorney General of Canada Ottawa, Canada   [1]   Income Tax Act, RSC 1985, c.1 (5 th supplement), as amended. [2]   Exhibit AR-1. [3]   Exhibit AR-2. ... Bodrug Estate v The Queen, [1990] 2 CTC 324 at 332, 90 DTC 6521 at 6526, ¶11 (FCTD); aff’d, [1991] 2 CTC 347, 91 DTC 5621 (FCAD). [64]   The Queen v Canada Trustco Mortgage Company, 2005 SCC 54, ¶74. [65]   Ibid., ¶74. ...
TCC

Bishara v. The King, 2022 TCC 105

Marin, 2005 CanLII 50228 (QC CQ) (“ Marin ”), in which the respondent challenged an assessment on the grounds that she had resigned as a director of the debtor company. ... The Queen, 2009 TCC 175 (“ Sandhu ”), in which Justice Jorré found that there was no evidence that the appellant had agreed to be a director and that there was an error in the initial declaration. ... For the Respondent: François Daigle Deputy Attorney General of Canada Ottawa, Canada   ...
TCC

Duncan v. The Queen, 2020 TCC 89

INTRODUCTION [1]    This is an Application to extend the time to file a Notice of Objection. ... Serota   Firm: BRS Tax Lawyers LLP Blank For the Respondent: Nathalie G. ... HMTQ, 2005 FCA 421, (leave to appeal to the SCC dismissed [2006] G.S.T.C. 44). [8] I note that, even if sent on the date of the Notice of Objection the Notice of Assessment would be timely in any event. [9] While there is no evidence to this effect, theoretically counsel could have obtained it acting as the Applicant’s agent. ...
TCC

Colubriale c. La Reine, 2006 DTC 2577, 2004 TCC 578

Translation certified true on this 20 th day of January 2005. Colette Dupuis-Beaulne, Translator Citation: 2004TCC578 Date: 20040924 Docket: 2001-1102(IT)G BETWEEN: GIUSEPPE COLUBRIALE, Appellant, and HER MAJESTY THE QUEEN, Respondent. ... Fibers, the lease was $15,000 per month. [4]      The first building was destroyed by fire in 1989. ... Fibers had never been mentioned. [6]      The transfer of the title of ownership from the appellant to J.C. ...
FCA

Enns v. Canada, 2025 FCA 14

WALKER J.A.   BETWEEN:     MARLENE ENNS     Appellant     and     HIS MAJESTY THE KING     Respondent   Heard at Edmonton, Alberta, on October 22, 2024. ... WALKER J.A.   BETWEEN:     MARLENE ENNS     Appellant     and     HIS MAJESTY THE KING     Respondent   REASONS FOR JUDGMENT WEBB J.A. [1] This is an appeal from the Judgment of the Tax Court of Canada (2023 TCC 28, per Russell J.) that dismissed Marlene Enns’ appeal from the assessment issued under section 160 of the Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.) ... Canada, 2005 SCC 54, at para. 10). A. Textual Analysis [27] In both The New Shorter Oxford English Dictionary on Historical Principles (1993 Edition) [New York: Oxford University Press Inc.] and B. ...

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