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Paragraph 8 of the Reply, reads: 8.          In so assessing and confirming the Appellant, the Minister relied on the following assumptions of fact:             a)      The Appellant is a financial institution;             b)     The Appellant contracted with various collection agencies in order to collect payment by its debtors who were in default;             c)      The task of the collection agencies was to recover and deposit the amounts in a trust account, the beneficiary of which was the Appellant;             d)     Within the parameters established by the Appellant these collection agencies could accept a lesser amount of the debt as a final settlement;             e)      In exchange for these services, the collection agencies receive a percentage of the amounts thus recovered. ... Judgment in that appeal has been reserved. [7]      Mr. Ezri's arguments on this point are as follows: There are three reasons why these cases should be heard in the usual manner rather than under Rule 58: 1)       The issue raised by this motion was the subject of a full trial on November 30, 2005 involving one of the same appellants. ... The collection services rendered by the collection agencies constitute financial services because they are described in any of the following paragraphs of the definition of "financial service" found in subsection 123(1) of the ETA:          (a)      the...receipt or transfer of money, whether effected by the exchange of currency, by crediting or debiting accounts or otherwise [...];          (d)      the...variation, transfer of ownership or repayment of a financial instrument (i.e., the debt securities giving rise to the amounts owing) [...];          (f)       the payment or receipt of money as...interest, principal...or any similar payment or receipt of money in respect of a financial instrument (i.e., the debt securities giving rise to the amounts owing) [...];          (l)       the agreeing to provide, or the arranging for, a service referred to in any of (the above) paragraphs [...]. [11]     Counsel referred to certain decisions of this court in which applications under section 58 of the Rules were considered: Webster et al. v. ...

L-15 (" LA ") [1], from taking tax collection action against the applicant? ... This would permit the CCRA to take collection action against the applicant for the 1990 and 1991 tax debts up to March 2005. [10]            Pursuant to the reasoning of the majority in Markevich, supra, the alleged federal tax debt of the applicant arises pursuant to federal legislation, that is the Income Tax Act, R.S.C. 1985, c. 1 (5 th Supp.) ... Costs to the applicant.    " Richard G. Mosley "    F.C.J.                                      ...

The respondent is entitled to costs.                     Signed at Ottawa, Canada, this 2 nd day of March, 2007. ... Factual background [7]      The driving force behind these transactions was a Calgary businessman by the name of Sig Gutsche. [8]      In the late 1980s, Mr. ... The Queen, 2005 D.T.C. 1280 (T.C.C.), at para. 22 to 35. The statutory purpose test [38]     The appellant submits that he incurred an expense of $50,000 in each of the relevant taxation years for the purpose of oil and gas exploration. [39]     The principal provision at issue is paragraph (a) of the definition of CEE in s. 66.1(6), which reads: "Canadian exploration expense" of a taxpayer means any expense incurred after May 6, 1974 that is (a)    any expense including a geological, geophysical or geochemical expense incurred by the taxpayer (other than an expense incurred in drilling or completing an oil or gas well or in building a temporary access road to, or preparing a site in respect of, any such well) for the purpose of determining the existence, location, extent or quality of an accumulation of petroleum or natural gas (other than a mineral resource) in Canada, [...] ...

[OFFICIAL ENGLISH TRANSLATION]   Appeal heard on April 28, 2015, at Montréal, Quebec. ... Canada, 2005 FCA 425, the burden of proof that rests on the taxpayer to rebut the Minister’s assumptions of fact is not to be lightly, capriciously or casually shifted. ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

The Queen, 2004 FCA 158, para 33 (informal proceeding) (“ 9103-9438 Quebec Inc. ”). [21]   I will therefore consider the comparison method for the purposes of this analysis. [22]   First, note that the Court is free to accept, in whole or in part, any expert opinion about the building’s FMV or to estimate its value itself, given the acceptable evidence: Petro Canada v. ... The Queen, 2005 TCC 622, paras 45, 46 and 65. This proposition seems essential enough, since the ultimate outcome of the comparison method is to find sales that approximate the property under review as much as possible. ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

VII.   Conclusion [36]   For these reasons, the decision rendered by the RAD was reasonable. ... Francie Gow, BCL, LLB FEDERAL COURT SOLICITORS OF RECORD DOCKET: IMM-1340-19   STYLE OF CAUSE: NOELLA NTETA-TSHAMALA v THE MINISTER OF CITIZENSHIP AND IMMIGRATION   PLACE OF HEARING: Montréal, Quebec   DATE OF HEARING: AUGUST 20, 2019   JUDGMENT AND REASONS: PAMEL J.   DATED: septembEr 20, 2019   APPEARANCES: Myriam Roy L’Ecuyer   FOR THE APPLICANT Anne-Renée Touchette   FOR THE RESPONDENT SOLICITORS OF RECORD: Étude légale Stewart Istvanffy Montréal, Quebec   FOR THE APPLICANT Attorney General of Canada Montréal, Quebec   FOR THE RESPONDENT   ...

Year Ended September 30 Gross Income Salaries Profits Profits 1969 NIL NIL NIL 1970 $ 3,458 — $ (3,921) 1971 65,235 — (14,977) 1972 275,200 16,000 11,362 1973 324,458 70,000 96,654 1974 982,744 79,334 443,408 1975 233,507 500,000 (225,999) 1976 306,596 100,000 69,253 1977 151,418 161,200 109,640 6. ... Mr Alfred Berry outlined the development and progress of the company, and in particular emphasized the reasons as he saw them — largely unexpected and external to the operations of the business — which brought about the business decline after 1974. ... G W Dorman Pulp Chip Company Ltd v MNR, [1981] CTC 2005; 81 DTC 21; 3. ...

He was the sole officer, director and shareholder. [19] In 2005, the Appellant purchased a parcel of land to build a custom home that became the family residence. ... The Queen, 2004 TCC 355 (“ Weyand ”), Justice Mogan explained it as follows: 11. ... Feder   Firm: Brazeau Seller Law Ottawa, Ontario   For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Ontario     ...

The Minister calculated the benefit endowed to the appellant (and her two brothers) as follows: Benefits to the beneficiaries (1/4) $32,500 Payment to Revenu Québec ($19,200) Adjusted benefit $13,300 Appellant’s benefit (1/3) $4,433 [13]         At the time the assessment was issued on January 27, 2014, Robert owed the Minister a tax debt for the 2004, 2005, 2006 and 2007 taxation years, totalling $28,938.46. ... Pentney Deputy Attorney General of Canada Ottawa, Canada     APPENDIX Civil Code of Québec SQ, c C-12 613. ... No. 194, at paragraph 40. [7]               See note 4, above, at paragraph 19. [8]               Riverin v. ...

(hereinafter “9158”) was incorporated on July 15, 2005, as a subsidiary of 9102, which holds 100% of the issued shares; On February 1, 2006, 9102 took out a joint universal life insurance policy on the lives of the appellant and Conrad Morissette, the appellant’s father. ... 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. [31]   The respondent also cited Telus Communications (Edmonton) Inc. v. ... Drouin Deputy Attorney General of Canada Ottawa, Canada   ...