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TCC
Hot Spot Restaurant Inc. v. The Queen, 2014 TCC 318
Peter Danakas passed away in October 2005. Voula’s brother, Leo Georgopoulos and Jason’s father, Richard Weinkauf, also testified for the Appellants. ... After reviewing all of the evidence before me, I have concluded that the families received substantial payments from third parties. [47] I have concluded that between the time of the fire at Hot Spot in 1996 and the end of 1999 Voula received $107,614 comprising the following: − Loan from her brother Leo Georgopoulos of $7,800 on November 14, 1996. [21] − Loan from her cousin Maria Damianakou of $13,000 on January 10, 1997. [22] − Loan from her brother Leo Georgopoulos of $11,000 in March 1997. [23] − Loan from her brother Leo Georgopoulos of $8,300 on January 19, 1998. [24] − Loan from her friend Kiki Tsoukala of $8,000 in February 1998. [25] − Loan from her brother Leo Georgopoulos of $15,000 in May 1999. [26] − Distribution from the estate of Voula’s parents of $44,514 [27] on July 27, 1999. [28] [48] Peter passed away in October 2005. ... The Minister assumed that the $55,786 comprised the following: − Unreported till tape income- $29,210 − Unreported other income- $7,570 − Unreported bottle return receipts- $15,602 − Over-claimed cost of sales expense- $3,404. [66] [83] Further, the $29,210 of purported unreported cash register till tape income was broken down into the following categories: − Unreported house sales reported on till tapes- $1,521 − Unreported till tape income missing from sales journal- $26,744 − Unreported income per sales journal/till tapes compared to amounts reported- $946. [67] [84] The Federal Court of Appeal noted the following in Newmont Canada Corporation v. ...
TCC
Hull v. The Queen, 2021 TCC 87
The Queen, 2021 TCC 87 Docket: 2015-2187(IT)G BETWEEN: JEFFREY HULL, Appellant, and HER MAJESTY THE QUEEN, Respondent. ... D’Arcy” D’Arcy J. CITATION: 2021 TCC 87 COURT FILE NO.: 2015-2187(IT)G STYLE OF CAUSE: JEFFREY HULL v. ... Christina Tari Firm: Tari Law Toronto, Ontario For the Respondent: François Daigle Deputy Attorney General of Canada Ottawa, Canada ...
TCC
Poopathie Company Ltd. v. The Queen, 2006 TCC 195 (Informal Procedure)
Nadarajah work long hours to run a viable business. [3] There are two issues. ... [24] I now turn to an issue dealing with amounts withdrawn from Mr. ... CITATION: 2006TCC195 COURT FILE NO.: 2004-4439(IT)I STYLE OF CAUSE: Poopathie Company Ltd. and Her Majesty the Queen PLACE OF HEARING: Toronto, Ontario DATES OF HEARING: December 2, 2005, February 9 and 10, 2006 and March 8, 2006 REASONS FOR JUDGMENT BY: The Honourable Justice Judith Woods DATE OF JUDGMENT: March 13, 2006 APPEARANCES: Counsel for the Appellant: V. ...
TCC
Nicole L. Tiessen Interior Design Ltd. v. The Queen, 2021 TCC 29, aff'd 2022 FCA 53
Doucette Counsel for the Respondent: John Krowina JUDGMENT In accordance with the attached Reasons for Judgment; 1. ... Siobhan Monaghan” Monaghan J. Citation: 2021 TCC 29 Date: 20210407 Docket: 2015-3808(IT)G BETWEEN: NICOLE L. ... Following the Reorganization, everything was in a single place – the Partnership – because all operations were consolidated in the Partnership. [138] But, Mr. ...
TCC
Davies v. The Queen, 2016 TCC 104
Bocock Appearances: Counsel for the Appellant: Jack W. Millar John G. ... Relief Sought a) Appellant [1] The Appellant’s motion seeks relief on two grounds. ... The initial appeal concerned the Appellant’s 2005, 2006 and 2007 taxation years and involved the deductibility of certain capital cost allowance in respect of a purchased software licence. ...
TCC
Kosma-Kare Canada Inc. v. The Queen, 2015 TCC 182
The judge writes that Kosma‑Kare, despite the warning it received from the ARQ in 2005, agreed to work with people with no concern as to whether they had work permits or a social insurance number, thinking that the blame would be placed on the agencies with which it was working. ... The Queen, 2006 FCA 224, 2006 DTC 6450, paragraphs 42-43). [15] In Torres v. ... Pentney Deputy Attorney General of Canada Ottawa, Canada [1] Subparagraph 152(4)(a)(i) and subsection 163(2) of the Income Tax Act are provisions that are equivalent to subsection 298(4) and section 285 of the ETA. ...
TCC
Comptois v. R., [1999] 2 CTC 2687
No opening. • 0 fine to union, 0 fine individuals — union to be responsible. • Rectify situation (regularize). ° 1992, 1993, 1994 amounts paid each year for each person involved in union. ° Revenue Quebec would have to follow.... ... R. (1996), 97 D.T.C. 487, [1997] I C.T.C. 2005 (T.C.C.). ° Regina Shoppers Mall Ltd. v. ... Cases cited by counsel for the respondent: ° Venne, supra. • Girard v. ...
TCC
Avenza Systems Inc v. M.N.R., 2007 TCC 507
., 2007 TCC 507 Citation: 2007TCC507 Dockets: 2006-2569(EI) 2006-2570(CPP) BETWEEN: AVENZA SYSTEMS INC., Appellant, and THE MINISTER OF NATIONAL REVENUE, Respondent. CERTIFICATION OF TRANSCRIPT OF REASONS FOR JUDGMENT Let the attached certified transcript of my Reasons for Judgment delivered orally from the Bench at Toronto, Ontario, on July 31, 2007, be filed. ... Weisman, Deputy Judge DATE OF ORAL JUDGMENT: July 31, 2007 APPEARANCES: Agent for the Appellant: Edward Florence Counsel for the Respondent: Annie Paré COUNSEL OF RECORD: Counsel for the Appellant: Name: Firm: For the Respondent: John H. ...
TCC
Swirsky v. The Queen, 2013 TCC 73, 2013 DTC 1078 [at at 431], aff'd 2014 FCA 36
Signed at Toronto, Ontario, this 28th day of February 2013. “B.Paris” Paris J. ... [26] The issues before the Court are: 1. Whether Ms. ... Swirsky had a reasonable expectation of income from the Torgan shares at the time she purchased them in 1991, 1993 and 1995, and that this expectation was borne out by the payment of dividends on the shares in 1999, 2003, 2004 and 2005. ...
FCA
The King v. MMV Capital Partners Inc., 2023 FCA 234
MONAGHAN J.A. BETWEEN: HIS MAJESTY THE KING Appellant and MMV CAPITAL PARTNERS INC. ... “I agree Judith Woods J.A. ” “I agree J.B. Laskin J.A.” FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD DOCKET: A-245-20 STYLE OF CAUSE: HIS MAJESTY THE KING v. MMV CAPITAL PARTNERS INC. PLACE OF HEARING: tORONTO, oNTARIO DATE OF HEARING: October 31, 2023 REASONS FOR JUDGMENT BY: MONAGHAN J.A. ...