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The TCC denied deductions for business losses and upheld the gross negligence penalties assessed by the Minister of National Revenue (Minister). [2]                In filing his 2005 and 2006 income tax returns, Mr. ... He also filed a Request for Loss Carryback with his 2005 return and sought and received refunds in the aggregate amount of over $140,000.00 for the 2002 to 2006 taxation years. [3]                In upholding the disallowance of business losses, the TCC found that Mr. ... Engel admitted before the TCC that he conducted no business in 2005 and 2006. ...

Canada, 2005 SCC 54, [2005] 2 S.C.R. 601.   [27]            In its analysis, the Tax Court focused on the words “the principal purpose for the acquisition or disposition” in paragraph 95(6)(b). ... Li, Principles of Canadian Income Tax Law (5th ed. 2005), at page 569. ... "David Stratas" J.A.     “I agree      Pierre Blais C.J.”   ...

Introduction [1]                These are appeals from a judgment of a deputy judge of the Tax Court of Canada (the Judge) dated September 14, 2005 (reported at [2005] T.C.J. ... Conclusion [32]            These appeals should be allowed, the decision of the Tax Court of Canada dated September 14, 2005 should be set aside in part and the assessments for the 2002 and 2003 taxation years should be referred back to the Minister of National Revenue for reconsideration on a basis consistent with these reasons.  ... Malone"  J.A.   “I agree      A.M. Linden J.A.”   “I agree      M. ...

Canada, [2005] 1 S.C.R. 113, para. 7), he concluded that the tenant’s purpose in making the payment was to relieve itself of its obligation to pay the outstanding rent through the life of the lease (Reasons, para. 18). ... Canada [2005] 1 S.C.R. 113, para. 7: [i]n assessing whether the monies will be taxable, we must look to the nature and purpose of the payment to determine what it is intended to replace.  ... Deputy Attorney General of Canada   FOR THE RESPONDENT         ...

PELLETIER J.A.                         LAYDEN-STEVENSON J.A.   BETWEEN:   PATRICK NICHOLLS Appellant     and     CANADA (REVENUE AGENCY) & MINISTER OF NATIONAL REVENUE Respondents     REASONS FOR JUDGMENT     NOËL J.A ...   [3]                Dealing with the first issue, the appellant maintains that the effective limitation took effect on December 31, 2006 rather than December 31, 2005 (memorandum of the appellant, paras. 45 to 50) ... Rather, the Federal Court Judge held that these issues relate to distinct decisions made by the Minister (i.e., CCRA objection confirmation November 10, 2005; CRA objection confirmation November 16, 2006; CRA letter- denial of Allowable Business Investment Loss (ABIL) January 16, 2007; CRA last refund denial February 12, 2008), and that the time for seeking judicial review of these decisions has expired. ...

Appellant and   MINISTER OF NATIONAL REVENUE Respondent       Heard at Toronto, Ontario, on March 20, 2007. ... (“LJP”) from a decision by Justice Mactavish of the Federal Court dismissing an appeal from an order of Prothonotary Milczynski, dated October 25, 2005, granting a motion by the Minister of National Revenue to strike LJP’s application for judicial review on the ground that it was bereft of any possibility of success.  ...   [10]            For these reasons, the appeal will be dismissed with costs.     ...

TALL Respondents       Heard at Toronto, Ontario, on January 11, 2007. ... Canada, 2005 TCC 765) dismissing its motion for leave to intervene in the income tax appeal of the respondent Franklin D. ... TALL                                                                                                                              Respondents   PLACE OF HEARING:                TORONTO, ONTARIO   DATE OF HEARING:                 JANUARY 11, 2007   REASONS FOR JUDGMENT BY:                                                SHARLOW, J.A.                 ...

SEXTON J.A.                                    SHARLOW J.A.                             BETWEEN:   ARTHUR ROMAN ZINS   Appellant and   HER MAJESTY THE QUEEN   Respondent         Heard at Toronto, Ontario, on October 3, 2007. ... Zins’ appeal to the Tax Court of Canada was allowed in part by Justice Miller, to reduce the income inclusion from $98,360 to $43,414 (2005 TCC 786). ...

Canada, 2005 SCC 54,  [2005] 2 S.C.R. 601  at para. 10, Re Rizzo & Rizzo Shoes Ltd., [1998] 1 S.C.R. 27, 154 D.L.R. (4th) 193 and  Bell ExpressVu Limited Partnership v. ... Alberta (Energy & Utilities Board),  2006 SCC 4,  [2006] 1 S.C.R. 140  at para. 48;  Montréal (City) v. 2952-1366 Québec Inc.,  2005 SCC 62,  [2005] 3 S.C.R. 141  at para. 10; see also  CIBC World Markets Inc. v. ... HER MAJESTY THE QUEEN     PLACE OF HEARING: Ottawa, Ontario   DATE OF HEARING: June 9, 2020   REASONS FOR JUDGMENT BY: STRATAS J.A.   ...

Canada, 2005 FCA 16. [6]                Ms. Eaton argues that she should not be treated as having received retroactive salary because the federal government has not made a retroactive adjustment for the overtime and acting pay that she earned while she was a government employee, and because the pension benefits to which she is entitled under the Canada Pension Plan (CPP) have not been increased to reflect what the federal government says is a higher retroactive salary. [7]                For the purposes of this appeal, we do not need to determine whether Ms. ... DELIVERED FROM THE BENCH BY:                             SHARLOW J.A.     APPEARANCES:   Eugenie Eaton   ON HER OWN BEHALF   Jeff Pniowsky   FOR THE RESPONDENT     SOLICITORS OF RECORD:   Eugenie Eaton ON HER OWN BEHALF   John H. ...