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Little had regular contacts with the CCRA with respect to Litmar's outstanding debt, [1] it was not until April 19, 2005 that he requested, on behalf of Litmar, a relief from interest and penalties. [4]                By that time Mr. ... Issues [11]            In his application, Mr. Little appears to contest the validity of the third party assessment of February 15, 2005 on the basis that he was duly diligent. ... Canada [2005] T.C.J. No. 220; Franck v. Canada [2005] T.C.J. No. 291). [15]            The assessment of Litmar has not been the subject of an objection or an appeal to the Tax Court of Canada. ...

Applicant- and- THE MINISTER OF PUBLIC SAFETY AND EMERGENCY PREPAREDNESS (CANADA) Respondent REASONS FOR JUDGMENT AND JUDGMENT O'KEEFE J. [1]                This is an application for judicial review of a decision of the Canada Border Services Agency (the CBSA) in two detailed adjustment statements dated January 27, 2005 (the DASs). ... [19]            Issue 1             What is the appropriate standard of review?             ...                                                            - and-                                                             THE MINISTER OF PUBLIC SAFETY AND                                                             EMERGENCY PREPAREDNESS (CANADA) PLACE OF HEARING:                     Toronto, Ontario DATE OF HEARING:                       November 14, 2005 REASONS FOR JUDGMENT:        O'KEEFE J. ...

       (2) Where an affidavit is made on belief, an adverse inference may be drawn from the failure of a party to provide evidence of persons having personal knowledge of material facts.       […]   82.  ... In addition, the applicants submit that provisions of the Income Tax Act are to be construed strictly (Burrows v The Queen, 2005 TCC 761 at para 45, 2006 DTC 2172 [Burrows]) and that, in the present case, the CRA violated section 231.2 of the Income Tax Act by failing to serve a notice personally or by registered or certified mail. ... The respondent further notes that the statutory scheme under the Income Tax Act for objecting to an appeal from assessments is a complete code (Walker v Canada, 2005 FCA 393 at para 11, 344 NR 169) and that judicial review should not be used as a mechanism to circumvent the jurisdiction of the TCC with respect to the determination of the validity of a tax assessment (Canada v Addison & Leyen Ltd, 2007 SCC 33 at para 11, [2007] 2 S.C.R. 793) ...

BETWEEN:   THE MINISTER OF NATIONAL REVENUE       Applicant   and       FRIENDS OF GOOGOLPLEXION FOR HUMAN RIGHTS INC. ... Respondent                      REASONS FOR JUDGMENT AND JUDGMENT   I. ... Keeping large amounts of cash, untraceable through normal banking records, in the trunk of an automobile (Minister of National Revenue v Arab, 2005 FC 264, [2005] 2 CTC 107 at para 20); c.    ...

In 2005, it had a multitude of importations.   [7]                Generally speaking, an importer of goods is required to report and declare, and pay such duty and general sales tax as may be owing. ... Powell’s imports for the year 2005.  It had a four-year window of opportunity to do so under the Act. ...   [30]            The decision of the Supreme Court in Vaughan v. Canada, 2005 SCC 11, [2005] 1 S.C.R. 146, stands for the proposition that the power of a Superior Court to intervene before the recourse provisions in a statute have run their course is not completely ousted if the recourse is not to an independent decision-maker. ...

Canada, [2005] F.C.J. No. 1039, 2005 FCA 228) [20]            In that regard, at paragraph 24 of the decision, Robert Décary J.A. said: In the circumstances, it would be both useless and rash to go beyond what is satisfactory to the parties. ... Canada, [2005] 1 S.C.R. 146 at paras 27–29, subsection 96(3) of the PSSRA is not a complete privative clause that may influence the deference to be granted to the decision-maker. [29]            As I have already said, the purpose of the Act is the administration and management of CSIS. ... HER MAJESTY THE QUEEN       PLACE OF HEARING:                    MONTRÉAL   DATE OF HEARING:                      JANUARY 10, 2006   REASONS OF JUDGMENT:          GAUTHIER J.   ...

Canada (Customs and Revenue Agency), [2005] F.C.J. No. 350. I must confess to some difficulty in reconciling the two cases. ... DAVID MORTON       PLACE OF HEARING:                     Vancouver, BC   DATE OF HEARING:                       May 7, 2007       REASONS FOR ORDER AND ORDER:                           STRAYER D.J.   DATED:                                                                                  May 9, 2007       APPEARANCES:   Ms. ...

Justice O'Keefe   BETWEEN: ALLAN JAY GORDON Plaintiff and   HER MAJESTY THE QUEEN IN RIGHT OF CANADA Defendant   Docket:  T-474-06   BETWEEN:   JAMES A. DEACUR & ASSOCIATES LTD. and JAMES ALLAN DEACUR   Plaintiffs  -          and –   HER MAJESTY THE QUEEN IN RIGHT OF CANADA   Defendant     REASONS FOR ORDER AND ORDER O’KEEFE J ... Canada (Attorney General), [2005] G.S.T.C. 70, 2005 FC 1479 at paragraphs 15 and 16 where he stated: 15.      ...

Background [2]                In a statement of claim filed in October 2005, the plaintiff Eclipse International Fashions Canada Inc. ...   “ Richard Morneau ” Prothonotary   Montréal, Quebec April 25, 2007 FEDERAL COURT   SOLICITORS OF RECORD       DOCKET:                                           T-1838-05   STYLE OF CAUSE:                           ECLIPSE INTERNATIONAL FASHIONS CANADA INC.                                                             ... Leung   FOR THE DEFENDANT   SOLICITORS OF RECORD:   Dagenais Jacob Montréal, Quebec   FOR THE PLAINTIFF Shapiro Cohen Ottawa, Ontario   FOR THE DEFENDANT   ...

Lauzon’s 2005 and 2006 refunds, correspond with PSPC’s “completed dates” for the PRN numbers associated with the 2005 and 2006 refunds. ... "Elizabeth Walker" Judge FEDERAL COURT SOLICITORS OF RECORD DOCKET: T-1970-18   STYLE OF CAUSE: PAUL LAUZON v CANADA REVENUE AGENCY   PLACE OF HEARING: HELD BY VIDEOCONFERENCE BETWEEN OTTAWA, ONTARIO (THE Court) and Toronto, Ontario (The Parties)   DATE OF HEARING: OCTOBER 5, 2020   JUDGMENT AND REASONS: WALKER J.   DATED: MAY 12, 2021   APPEARANCES: Jeffrey Radnoff Charles Haworth   For The Plaintiff   Nancy Arnold Angela Shen   For The Defendant   SOLICITORS OF RECORD: Radnoff Law Offices Barristers and Solicitors Toronto, Ontario   For The Plaintiff   Attorney General of Canada Toronto, Ontario   For The Defendant     ...