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Accordingly, the date of payment could simply not have been June 10, 1995 for the purposes of crediting the Overpayment to the taxpayer’s 1993 tax liability. [11]         I frankly do not agree with the Appellant’s interpretation of the plain meaning of subsection 187(2) and find no ambiguity in the interpretation of same; however even if I agree that the Appellant’s position creates an ambiguity in interpretation, I could not find in the Appellant’s favour based on a textual, contextual and purposeful approach to interpretation for several of the reasons the Respondent has well argued. [12]         Both parties relied on the Supreme Court of Canada’s decision in Canada Trustco Mortgage Co v Canada, [2005] 2 SCR 601, 2005 SCC 54 for the principles of statutory interpretation found at paragraph 10:    It has been long established as a matter of statutory interpretation that “the words of an Act are to be read in their entire context and in their grammatical and ordinary sense harmoniously with the scheme of the Act, the object of the Act, and the intention of Parliament”: see 65302 British Columbia Ltd. v. ... Pizzitelli DATE OF JUDGMENT: February 12, 2015   APPEARANCES:   Counsel for the Appellant: Matthew G. ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

(ii)       He did not know the other associates of the partnership. (iii)      He did not participate in any associates meetings. ... Papion [13]     In December 2005, Claude Papion, a computer expert, was mandated by the Respondent to carry out an assessment of the requests regarding the partnership's scientific research activities using the documentation submitted by the partnership and the documentation related to the assessment of admissibility of the partnership's prior research work, carried out by Georges Husson, external scientific reviser who had done work for Revenue Canada. ... This report dated January 17, 2005, was submitted as evidence by the Respondent (Exhibit I-1). ...

Minister of National Revenue, 2013 FCA 250; Addison & Leyen Ltd. v. ... The Queen, 2004 FCA 403 (leave to appeal denied 2005 CarswellNat 1110 (S.C.C.)). [5] Ruremesha v. ... The Queen, 2005 TCC 330, at para. 27. [20] 2015 SCC 41. [21] Gratl v. ...

Therefore, subsection 152(7) of the Income Tax Act, RSC 1985, c.1, as amended (the “ Act ”) was deployed. ... The receipt covered the precise period, from 2005 when the cash was received until 2019. ... Burke’s house sale upon marriage breakdown in 2005. He said this amount, some $37,000 by the court’s arithmetic, was retained and used when needed. ...

Weisman, Deputy Judge   Appearances:     Counsel for the Appellant: R. ... Weisman" Weisman D.J.           Citation: 2008 TCC 470 Date: 20080825   Dockets: 2007-1674(EI) 2007-1675(CPP) BETWEEN: OLTCPI INC.,   Appellant, and   THE MINISTER OF NATIONAL REVENUE,   Respondent.   ...   [2]      Renu Arora is a Registered Dietician. In July 2005, she responded to OLTCPI’s advertisement on the Dieticians of Canada website, which sought a dietician for Leisureworld’s Lawrence Avenue facility in Toronto. ...

Canada, 2005 FCA 425, [2005] G.S.T.C. 200, the Federal Court of Appeal held that there is a very simple and pragmatic reason as to why the burden is on the taxpayer. ... [Emphasis added.] [21]         In Ruest v. The Queen, 1999 CanLII 346 (TCC), the assessments were made using the ‟ net worth ˮ method as the appellant had no bookkeeping or accounting system for his business. ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...

Lyons   Appearances:   Agent for the Appellant: Anthony Kokai-Kuun Counsel for the Respondent: Karen Truscott   JUDGMENT           The appeal from the reassessment made under the Income Tax Act for the 2008 taxation year is dismissed.             ... According to the loans spreadsheet, by 2005, the outstanding amount due to Zoltan totalled $233,751.79 and that reduced to $218,751.79 as at 2006 after a $15,000 repayment was made to Zoltan. [37]         On June 20, 2006, Zoltan sold his 24 shares to Ms. ... the taxpayer elects in his return of income for the year to have the subsection apply. [55]         In Harris v The Queen, 2005 TCC 501, 2005 DTC 1179, Sheridan J. found that the failure by Ms. ...

.____________________________________________________________________ Appeals heard on November 21, 2005, at Sudbury, Ontario, By: The Honourable Justice E.A. ... Deputy Attorney General of Canada Ottawa, Canada [1]           R.S. 1996, c.23, as amended. [2]           R.S.C. 1985, c. ... M.N.R., 87 DTC 5025. [6]           Market Investigations Ltd. v. Minister of Social Security, [1968] 3 All E.R. 732 (Q.B.D.). [7]           supra, at paragraphs 47 and 48. [8]           [1929] S.C.R. 166 at 168. [9]           [1947] 1 D.L.R. 161. [10]          [2002] FCA 207. [11]          2004 TCC 23. ...

Translation certified true on this 26 th day of January 2005. Colette Dupuis-Beaulne, Translator Citation: 2004TCC593 Date: 20041015 Docket: 2003-4470(IT)I BETWEEN: GILLES BÉGIN, Appellant, and HER MAJESTY THE QUEEN, Respondent. [OFFICIAL ENGLISH TRANSLATION] REASONS FOR JUDGMENT Archambault J. [1]      Mr. ... Bégin provides this explanation: [TRANSLATION] [...] During an attack of cataplexy: (1)         Vision becomes blurred and eyelids drop, eyes roll back. (2)         Walking requires holding on before bending and standing still. (3)         Speech is illogical even though senses remain active... language remains irrational. (4)         Mental faculties (perceiving, thinking and remembering) are seriously affected by this decrease in alertness and concentration. [18]     I therefore conclude that, although Mr. ...

The Queen, 2013 DTC 1018 [at at 93], 2012 TCC 406, rev'd supra         Citation: 2012 TCC 406 Date: 2012 1214 Docket: 2010-1429(IT)G   BETWEEN: ALLEN BERG, Appellant, and   HER MAJESTY THE QUEEN, Respondent.       ...   [29]       In Webb v. R., 2004 TCC 619, [2005] 3 C.T.C. 2068 (T.C.C. ... Pentney                                                           Deputy Attorney General of Canada                                                           Ottawa, Canada [1]  92 DTC 6031 (F.C.A.) [2] [1997] 2 C.T.C. 2557 [3] 2004 TCC 438, [2004] 3 C.T.C. 2297 [4] 2009 TCC 587, [2010] 2 C.T.C. 2099 [5] 2010 FCA 287, 2010 DTC 5174(FCA) [6] 2004 TCC 619, [2005] 3 C.T.C. 2068 [7] 2010 TCC 142, [2010] 5 C.T.C. 2035 [8] 2011 ONCA 533, 335 DLR (4 th) 704 [9] 2012 TCC 325 ...