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Judgment debtors     ASSESSMENT OF COSTS – REASONS     ASSESSMENT OFFICER JOHANNE PARENT   [1] On October 21, 2005, the Court (Mr. ... A certificate of assessment will be issued for this amount.       “Johanne Parent” Assessment Officer   Toronto, Ontario March 16, 2010 FEDERAL COURT   SOLICITORS OF RECORD     DOCKET:   T-1847-05   STYLE OF CAUSE:   I n the matter of the Income Tax Act, v. ... ASSESSMENT OF COSTS IN WRITING WITHOUT PERSONAL APPEARANCE OF THE PARTIES     PLACE OF ASSESSMENT:   TORONTO, ONTARIO     ASSESSMENT OF COSTS – REASONS:   ASSESSMENT OFFICER   JOHANNE PARENT   DATE OF ASSESSMENT:       MARCH 16, 2010     WRITTEN REPRESENTATIONS BY:   Sophie Matte FOR THE APPLICANT   N/A   FOR THE JUDGMENT DEBTORS   SOLICITORS OF RECORD:   John H. ...

  [15]            In a letter to the Applicant dated June 7, 2005, eighteen (18) months after the Fairness request was submitted, Ms. ... Canada (Customs & Revenue Agency) 2005 FCA 271, (2005), 361 N.R. 141 (F.C.A.) at paragraph 16. ... Canada (Minister of National Revenue- M.N.R.), 2005 FC 1201, [2005] 4 C.T.C. 233 (F.C.); Dobson Estate v. ...

  [5]                In a letter dated May 27, 2005, Ms. Paula Fuerst, on behalf of CRA, informed the Applicants that the waiver was retracted as Mr. ...     [6]                The Applicants are now seeking an order of mandamus compelling CRA to comply with the decision dated February 16, 2005 whereby the Applicants’ request for a waiver was granted with respect to the 2000 taxation year. ... The decision of May 27, 2005 purporting to revoke the waiver dated February 16 th, 2005 is hereby set aside; and (2)                  (3)                3.         ...

  [3]                            Subsequently, the applicant objected to the notices of assessment dated January 31, 2005, for the additional income thus attributed to the 2001 and 2002 taxation years. ...   [4]                            On February 4, 2005, von Finckenstein J. determined that, according to the sworn statement of François Bacave, a collections officer at an Agency tax services office, there were reasonable grounds to believe that granting Mr.  ... Bacave for obtaining the order in 2005 and in 2006. The reasons taken from the statement are also relevant for both applications. ...

That decision was documented in a letter dated January 4, 2005 from the Director of the Northern British Columbia and Yukon Tax Services Office, Don Salmons. ... Canada (Customs and Revenue Agency) [2005] F.C.J. 714, 2005 FCA 153 (C.A.). [8]         The Record discloses a degree of sloppiness and imprecision in CRA's approach to Mr. ... AGC             PLACE OF HEARING:                     Van couver, British Columbia DATE OF HEARING:                       May 9, 2005       REASONS FOR ORDER AND ORDER:                                    BARNES, J        DATED:                                             May 25, 2006 APPEARANCES: Mr. ...

He worked at the BFTSO from 1994 until April of 2005.   [4]                Mr. and Mrs. ... Novopharm Ltd. 2005 FC 815, (2005), at para. 59, aff'd 2005 FCA 390, 44 C.P.R. (4th) 326 ... Canada (Minister of National Revenue- M.N.R.), [2005] F.C.J. No. 1249, 2005 FC 1010 ...

Canada (Canada Revenue Agency), 2007 FC 1358     Date: 20071221 Docket: T-861-06 Citation: 2007 FC 1358 Ottawa, Ontario, December 21, 2007 PRESENT:     THE HONOURABLE MADAM JUSTICE DAWSON   BETWEEN:   ARTHUR ROMAN ZINS   Applicant   and   CANADA REVENUE AGENCY   Respondent     REASONS FOR JUDGMENT AND JUDGMENT   [1]         On December 8, 2005, the Tax Court of Canada issued its judgment in respect of Mr.  ... VISHNU PERSAUD / March 10, … The Honourable John McCallum … has asked me to reply to your letter of September 19, 2005 … if you choose to appeal to the next court level, adequate security in lieu of full payment would be satisfactory until the dispute is resolved … CRA may consider canceling or waiving interest if an individual is experiencing financial hardship … I note that … you are presently making monthly payments of $100 … It may be noteworthy that since the January 12, 2006 decision to suspend collections, there has been no further mention of any ‘adequate security in lieu’ associated with this suspension of collections.  ... Wong dated February 12 and March 1, 2005 … and confirmation of my job loss in mid July 2005 of a second job … and confirmation of some $2,000 in dental expenses … have all confirmed a continuing level of ‘impecuniosity’ justifying no further request for ‘adequate security in lieu’ …”   d)                   as there has been no response by CRA as to any consideration of their fairness procedure to the applicant’s case until the letter of August 9, 2006 (please refer to item 11 b) above), the applicant respectfully submits that CRA has unfairly and inequitably caused undue delay in not applying CRA’s fairness procedures in a substantiated forgiveness of all the applicant’s interest and penalties as to the tax debt in issue,   e)                   in reference to item 11 d) above, the applicant suggests it would be prudent for this Court to expedite an assessment of the applicant’s circumstances with a view to substantiating a forgiveness of all the applicant’s interest and penalties in issue.          ...

  [8]                According to the Fairness Request Summary of Facts, on January 25, 2005, the Canada Revenue Agency (CRA) commenced its first level review of the Applicant’s request for fairness ... Canada Customs & Revenue Agency (2005) 334 N.R. 348 (FCA)).   [20]            The first issue raised by the Applicant is in regards to the original cost base of the Amalgamated income shares invested in RCMF through a section 85 rollover. ... No. 1847; 15.               Lanno v. Canada Customs and Revenue Agency, (2005), 334 N.R. 348 (FCA); 16.               ...

This dynamic is such that it must be held that by the application of article 2843 of the Civil Code of Québec (C.C.Q.), Animation JL, in a way, consented to an exception to hearsay. [37] As stated by the author Léo Ducharme in Précis de la prevue, 6 ième  édition, 2005, Wilson & Lafleur Ltée, 702 pages, at paragraph 1347: [translation] 1347.   ... Instead, in 2005, he received $8,012 in employment insurance benefits. ... Deputy Attorney General of Canada Montréal, Quebec   FOR THE JUDGMENT DEBTOR MCMillan Binch Mendelsohn LLP Montréal, Quebec   FOR THE MIS EN CAUSE                 ...

  [9]                In Comeau c. Canada (Agence des Douanes et du Revenu), 2005 CAF 271, at para. 16, Justice Pelletier dealt with a decision based on subsection 220 (3.1) of the ITA, applied the decision of the Federal Court of Appeal in Lanno v. ... Canada, 2005 FCA 180 and Collins v. Canada, 2005 FC 1431).         [28]            As I mentioned in Collins, Bill C-30, An Act to Implement Certain Provisions of the Budget Tabled in Parliament on 23 March 2004, 3 rd Sess., 37 th Parl., 2004 (Received royal Assent on May 14, 2004) (“Bill C-30”) was adopted as a response to the Supreme Court of Canada’s decision in Markevich v. ...     [31]            I n the recent decision, Dikranian v. Quebec (Attorney General), [2005] S.C.J. ...