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Expressed in C$, these Redemptions gave rise to the following results: 2006 Redemptions Principal Amount at Issuance Principal Amount at Extinguishment FMV of Shares Issued $1,764,379 $1,282,205.10 $1,946,780 [20]            In its 2005 income tax return, the Taxpayer did not report any capital gains in respect of the Conversions that occurred in its 2005 taxation year. [21]            By Reassessment dated February 11, 2011 (the “2005 Reassessment”), the Minister reassessed the Taxpayer for its 2005 taxation year on the basis that, pursuant to subsection 39(2), the Taxpayer was deemed to have realized capital gains in the aggregate amount of $4,499,360 as a result of the 2005 Conversions. ... The Judge heard the Taxpayer’s appeals of the 2005 and 2006 Reassessments together. ... C.               Did the Judge commit a reviewable error in concluding that the Taxpayer did not make a gain for the purposes of subsection 39(2) as a result of the 2005 and 2006 Conversions? ...

DAWSON J.A.                         STRATAS J.A.   BETWEEN: DANIEL LAWRENCE FANNON Appellant and   REVENUE CANADA Respondent       Heard at Toronto, Ontario, on April 10, 2013. ... Fannon’s request for reassessments for the years 2001 to 2005. The reassessments were requested to allow deductions pursuant to section 63 of the Income Tax Act, R.S.C. 1985, c.1 (5 th Supp.) for child care expenses paid by Mr. ... APPEARANCES:   Daniel Lawrence Fannon FOR THE APPELLANT     Paolo Torchetti Arnold Bornstein FOR THE RESPONDENT     SOLICITORS OF RECORD:   Self-Represented FOR THE APPELLANT     William F. ...

Canada, 2006 FCA 177 Date: 20060511 Docket: A-479-05 Citation: 2006 FCA 177 CORAM:        LINDEN J.A.                         ... Date: 20060511 Docket: A-479-05 Citation: 2006 FCA 177 CORAM:        LINDEN J.A.                         ... The discussions were discontinued early in 2005. [5]                Meanwhile, examinations for discovery and other pre-trial matters have been pursued, to the point where the Crown now says it is ready for trial, subject to the appellants' compliance with certain undertakings. ...

GLEASON J.A.     BETWEEN: VINCENT DICOSMO Appellant and HER MAJESTY THE QUEEN Respondent REASONS FOR JUDGMENT OF THE COURT (Delivered from the Bench at Toronto, Ontario, on March 28, 2017) [1]                This is an appeal from the judgment of the Tax Court of Canada, whereby the Court dismissed the appellant’s challenge to the Minister’s reassessments for the 2003, 2004 and 2005 taxation years. The appellant claimed that the Minister erred in not allowing his claims for additional employment expenses, allowable business losses and a representation fee in respect of the 2005 taxation year. ... Pentney Deputy Attorney General of Canada For The Respondent             ...

NADON J.A.                         TRUDEL J.A.   BETWEEN: KATHRYN KOSSOW Appellant and HER MAJESTY THE QUEEN Respondent               Heard at Toronto, Ontario, on March 11, 2009. ... The Queen, 2005 TCC 556, at paragraphs 21 and 22, Chief Justice Bowman wrote:   [21]     With respect, I am unable to ascribe to either the Status-One decision or the case which it followed, The Queen v. ... Canada, 2005 FCA 104, at paragraph 35. I agree with the judge that it is premature to shift the onus of proof.   ...

LASKIN J.A.   BETWEEN:     CHRIS WALBY and JOEL DE LAS ALAS     Appellants     and     HIS MAJESTY THE KING     Respondent   Heard at Toronto, Ontario, on November 28, 2024. ... LASKIN J.A.   BETWEEN:     CHRIS WALBY and JOEL DE LAS ALAS     Appellants     and     HIS MAJESTY THE KING     Respondent   REASONS FOR JUDGMENT WEBB J.A. [1] Mr. ... Morrison participated in the CHT Program in 2004 and 2005. In reassessing Mr. ...

REASONS FOR JUDGMENT OF THE COURT BY:                                                     NOËL J.A.             ... Justice Dussault of the Tax Court of Canada on January 19, 2005, upholding in part the notices of assessment established in respect of the appellant for the taxation years 1994 to 1998. ... “Marc Noël” Judge           Certified true translation Michael Palles             FEDERAL COURT OF APPEAL   SOLICITORS OF RECORD       DOCKET:                                                                               A-58-05     STYLE OF CAUSE:                                                               MAYA FORESTALES v. ...

Subsequently, the Minister entered into agreements with Sifto to settle its income tax liability for its 2004, 2005 and 2006 taxation years. ... Ralph Misener (The), [2005] F.C.J. No. 612, 2005 FCA 139 at paragraph 13. ... Aventis Pharma Inc., [2005] F.C.J. No. 215, 2005 FCA 50, 38 C.P.R. (4th) 1 at paragraph 9. ...

SHARLOW J.A.                                 MALONE J.A. Docket: A-246-05 BETWEEN: WILLEM VANKERK Appellant and HER MAJESTY THE QUEEN Respondent Docket: A-247-05 AND BETWEEN: ELSBETH VANKERK Appellant and HER MAJESTY THE QUEEN Respondent REASONS FOR JUDGMENT OF THE COURT (Delivered from the Bench at Toronto, Ontario, on March 7, 2006) SHARLOW J.A. [1]                These are appeals from judgments of the Tax Court of Canada (2005 TCC 292) confirming reassessments of the appellants for the years 1986 through 1995. ... APPEARANCES:                               John W. McDonald                                           FOR APPELLANTS Harry Erlichman                                                 FOR RESPONDENT    Mr. John Pro SOLICITORS OF RECORD:           McDonald, Ross                           Cambridge, Ontari o                                           FOR APPELLANTS John H. ...

(the ITA) on June 11, 2010, for the 2004 and 2005 taxation years. The Judge held that since the income tax returns from the corporation 9073-8253 Québec Inc. ... SCOTT J.A.   DELIVERED FROM THE BENCH BY: SCOTT J.A.   APPEARANCES: Alexandre Duplessis   For the appellant (REPRESENTING HIMSELF)   Christina Ham   For the respondent   SOLICITORS OF RECORD: William F. Pentney Ottawa, Ontario   For the respondent     ...