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The Queen, 2005 TCC 96. After reviewing the relevant portions of Symes, Justice Lamarre summarizes key considerations in applying paragraph 18(1)(a) as follows: 16 Thus, in order to be deductible as business expenses, the expenses in question must have been incurred “for the purpose of gaining or producing income from the business” within the meaning of paragraph 18(1)(a) of the ITA. ... CITATION: 2017 TCC 114   COURT FILE NO.: 2016-2360(IT)I   STYLE OF CAUSE: PAVEL DANILOV v. THE QUEEN   PLACE OF HEARING: Hamilton, Ontario   DATE OF HEARING: February 22, 2017   DATE OF RECEIPT OF TRANSCRIPT OF HEARING: March 22, 2017   REASONS FOR JUDGMENT BY: The Honourable Justice Gaston Jorré   DATE OF JUDGMENT: June 20, 2017   APPEARANCES:   For the Appellant: The Appellant himself Counsel for the Respondent: John Maskine COUNSEL OF RECORD:     For the Appellant:     Firm:     For the Respondent: William F. ...

“Guy Smith” Smith J.   Citation: 2018 TCC 126 Date: 20180629 Docket: 2017-762(IT)I BETWEEN: LINDSAY FORTNUM, Appellant, and HER MAJESTY THE QUEEN, Respondent.   ... Canada, [2005] 2 S.C.R. 601: [10]   It has been long established as a matter of statutory interpretation that "the words of an Act are to be read in their entire context and in their grammatical and ordinary sense harmoniously with the scheme of the Act, the object of the Act, and the intention of Parliament": see 65302 British Columbia Ltd. v. ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

REASONS FOR JUDGMENT Masse D.J. [1]   The Appellant, Mr. Burley, appeals an assessment made under the Income Tax Act, RSC 1985, c 1 (5th Supp) (the “ Act ”), for his 2016 taxation year. [2]   Mr. ...   (3) … [19]     Under s. 9 of the Act, a taxpayer can deduct expenses that are incurred to earn that profit, subject to limitations set out in the Act. ... Leduc, 2005 TCC 96, a lawyer was charged with criminal offences of a sexual nature. ...

" The Pasture " [10]     In the taxation years in question, Mrs. ... " The Hayfield " [13]     Mrs. Wadley had an agreement with her neighbour to crop-share the Hayfield. ... In 2001 she harvested twenty-three 1200-pound bales and twenty in 2002; in 2005, when the rains returned, the same field produced some 242 bales. [16]     Because she shared the crop on a 50-50 basis with her neighbour, it follows that she was not as actively involved as she would have been if it had been exclusively her venture. ...

III.   Arguments and analysis [11]   The applicant makes three arguments. ... A.   Adequacy of reasons [12]   Let’s dispose first of the last argument. ... The applicant relies exclusively on the case of Rolfe v Canada (Minister of Citizenship and Immigration), 2005 FC 1514 for his proposition that the inadequacy of reasons can be a sufficient ground to be successful on judicial review. ...

The Applicant, her Husband, and her aunt all provided evidence that was unreliable and not credible. [8]   The IAD stated that it had considered several of the factors set out in Chavez v Canada (Citizenship and Immigration), 2005 CarswellNat 7250 (IAD) [Chavez], when assessing the genuineness of the marriage, the development of the relationship, and the evidence filed in support of the appeal. [9]   The IAD found that the evidence of the Applicant and her Husband was inconsistent in regard to numerous critical issues, which were contained in the forms they filed in support of the sponsorship application and, with respect to very basic elements regarding the genesis and development of their relationship. ... It was not necessary for the IAD to explicitly tie its analysis to each Chavez factor considered. [24]   The Applicant also submits that the tests for genuineness of the relationship and the intent behind the marriage pertain to different time periods – the time of the hearing and the time of the marriage – neither of which coincide with the genesis of the relationship in this case. ... The IAD also considered the Husband’s immigration history. [28]   Thus, the IAD did consider post-wedding evidence in the context of its genuineness analysis. [29]   Further, as stated in Bercasio v Canada (Citizenship and Immigration), 2016 FC 244: [19]   As I understand Yadav, it stands for the proposition that the relevant time frame for assessing the genuineness of a marriage is at the time of the interview. ...

Ryan at 123, lines 7 – 28; at 124, lines 1 – 14; at 127, lines 9 – 28; at 128, lines 1 – 7. [8] Transcript, cross-examination of Mr. ... Ryan at 87, lines 19 – 28; at 88, lines 1 – 8; at 125, lines 20 – 28; at 126, lines 1 – 13. [11] Transcript, cross-examination of Mr. Ryan at 85, lines 15 – 19; at 87, lines 19 – 28; at 88, lines 1 – 8; at 125, lines 20 – 28; at 126, lines 1 – 13. [12] Transcript, examination of Ms. ...

The Queen (FCA) 1991 CarswellNat 520 [5]           McGowan v. The Queen (FCA) 1995 CarswellNat 381 in obiter at para 19 [6]           Schafer (FCA) [7]           2011 TCC 39, at para 15 [8]           2016 TCC 102 [9]           2016 TCC 73 [10]          Carcone; Central Springs Ltd. v. ... The Queen 2016 FCA 68 [13]          Affidavit of Mr. Mpamugo dated December 29, 2015, para 3 [14]          On cross-examination, Mr. ... His evasiveness on this matter hurt his credibility. [17]          Exhibit R-8 [18]          Exhibit R-2, Tab 2B [19]          Exhibit R-11 [20]          Exhibits R-6 and R-7 [21]          Exhibit R-9 [22]          Exhibit R-4 [23]          I find that he was being held pending bail from November 5-17, 1999, held for a breach of his bail conditions from October 29 – December 1, 2001 and in prison following his sentencing from December 9, 2004 to December 9, 2005. [24]          1995 CarswellNat 278, [1995] 1 CTC 327 [25]          Exhibit R-13 ...

He testified that advertising was through the use of business cards, contacts at dog shows and flyers, though he did not provide any examples of the latter. [10]          The following is a schedule of the losses over the years:   Gross business income Net business loss for the Savages 1999 $1200 $12460 2000 $1200 $12546 2001 $1200 $10604 2002 $3600 $17240 2003 $3600 $7656 2004 $3600 $6558 2005 $3600 $13442 2006 $4800 $8178 2007 $4800 $8032 2008 $1050 $29384 2009 $0 $28974 2010 $1750 $13394 2011 $2500 $21,438 2012 $1600 $15890 2013   $4000* 2014   $2500* 2015   $1900* 2016   $1600* * Unclear whether this was for each of Mr. ... Miller DATE OF JUDGMENT: December 7, 2017   APPEARANCES:   For the Appellants: The Appellants themselves Counsel for the Respondent: Hye-Won (Caroline) Ahn   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: Nathalie G. Drouin Deputy Attorney General of Canada Ottawa, Canada     [1]           2002 SCC 46. [2]           [1994] 1 CTC 2127. [3]           [1996] 1 CTC 2634. ...

In 2005, the PMRA gave approval to a label expansion which allowed it to be used as a pre-harvest desiccant on a variety of crops including chickpeas. [8]   In 2009, the PMRA gave notice of its intention to re-evaluate glyphosate. ... B.   Issue II – Dietary Consumption Data [52]   The Applicants’ concern was that outdated data were used.   ... DATED: February 13, 2020   APPEARANCES: Andrea Gonsalves Emily Quail   For The Applicants   Andrea Bourke Elizabeth Koudys   For The Respondent   SOLICITORS OF RECORD: Stockwoods Barristers and Solicitors Toronto, Ontario   For The Applicants   Attorney General of Canada Toronto, Ontario   For The Respondent     ...