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TCC
Hébert c. La Reine, 2004 TCC 760
Translation certified true on this 18 th day of July 2005. Colette Dupuis-Beaulne, Translator Docket: 2001-2721(IT)G BETWEEN: MICHEL HÉBERT, Appellant, And HER MAJESTY THE QUEEN, Respondent. ... Translation certified true on this 18 th day of July 2005. Colette Dupuis-Beaulne, Translator Citation: 2004TCC760 Date: 20041213 Docket: 2001-2721(IT)G BETWEEN: MICHEL HÉBERT, Appellant, and HER MAJESTY THE QUEEN, Respondent, AND BETWEEN: Docket: 2001-2720(IT)G 91633 CANADA LTÉE, Appellant, and HER MAJESTY THE QUEEN, Respondent. ... " A. Yes. Q. They ask you? A. Yes. Q. ...
TCC
van der Steen v. The Queen, 2016 TCC 205
Leung; b) any settlement offers that might be contemplated or that might arise; and c) the appeals of taxpayers other than the Appellant. ... Sommerfeldt DATE OF ORDER AND DIRECTION: September 19, 2016 APPEARANCES: COUNSEL OF RECORD: For the Appellant: Name: Alec McLennan Firm: McLennan & Associates For the Respondent: William F. ... The Queen, 2005 TCC 635, ¶31; aff'd, 2006 FCA 177. [10] Law Society of Upper Canada, Rules of Professional Conduct of the Law Society of Upper Canada, section 4.04, as quoted in Scavuzzo v The Queen, 2004 TCC 806, ¶14. [11] Scavuzzo, ¶15. [12] R. v Coffin, [1956] S.C.R. 191. [13] Ibid. ...
TCC
J. Hudon Enterprises Ltd. v. The Queen, 2008 TCC 348
The Queen, 2008 TCC 348 Docket: 2004-3932(GST)G BETWEEN: J. ... April 2005 was his last one. He has been involved in the industry since 1982. ... [34] She identified Exhibit A-2 which is a letter written to her from the Rulings Department of Revenue Canada dated November 23, 2005. ...
TCC
SLX Management Inc. v. The Queen, 2010 TCC 148
Stewart and Nandini Somayaji Counsel for the Respondent: Mark Heseltine____________________________________________________________________ JUDGMENT The appeals from the reassessments made under the Income Tax Act for the 2002, 2003, 2004 and 2005 taxation years and the appeal from the reassessment made under the Excise Tax Act, notice of which is dated July 31, 2006 in respect of the period of September 17, 2001 to September 16, 2003, are allowed, and the reassessments are referred back to the Minister of National Revenue for reconsideration and reassessment in accordance with the attached Reasons for Judgment. ... Signed at Ottawa, Canada, this 12th day of March, 2010. “E.P. Rossiter” Rossiter A.C.J. ... Miller’s spouse, Barbara, accompanied him on many of the flights. ...
TCC
Wynter v. The Queen, 2016 TCC 103
When she received a further letter from CRA – dated May 6, 2011 – Tab 9 – she sent it to Gilmore. ... Between 1999 and 2005, she had not paid Grouter more than $100 as a fee and had not paid him or any previous preparer a percentage of a refund. ... Pentney Deputy Attorney General of Canada Ottawa, Canada ...
TCC
Stack v. The King, 2024 TCC 163, 2024 TCC 164
INTRODUCTION PART ONE – MOTIONS TO COMPEL A tale of two motions to compel [1] Mrs. ... R [58] and stated that “[…] once an unqualified undertaking has been given, it is too late to refuse to provide an answer on grounds of relevance […]”. ... Canada, 2005 SCC 54 at para 44. [97] Birchcliff Energy Ltd. v. R, [2013] 3 C.T.C. 2169 at para 15; MP FCA, supra note 6 at para 28. [98] Superior Plus, supra note 29 at para 21. [99] MP FCA, supra note 6 at para 27. [100] Burlington TCC 2015, supra note 2 at para 54. [101] Coopers Park Real Estate Development Corporation v. ...
TCC
Atlantic Thermal Star Limited v. The Queen, 2016 TCC 135 (Informal Procedure)
No evidence was offered to the effect that the fair market value of the goodwill should be of the same value at the beginning of 2005 and in September 30, 2006, namely 21 months after. ... McDonald Heidi Cullicutt COUNSEL OF RECORD: For the Appellant: Name: Firm: For the Respondent: William F. Pentney Deputy Attorney General of Canada Ottawa, Canada ...
TCC
Restaurant Loupy's inc. v. The Queen, 2016 TCC 260 (Informal Procedure)
The Queen, [2005] T.C.J. No. 492, in which Justice Miller made the following comment at paragraph 33 of his decision: […] The Respondent did not raise subsection 200(2) and I simply raise it to illustrate to Mr. ... The Queen, 2007 TCC 155, in which Justice Paris ruled in favour of the appellant regarding its claim for input tax credits, because, in his view, the claim met the regulatory requirements of section 169 of the ETA. [81] In Westborough Place Inc., supra, the main issue was that on December 23, 2005, the Minister had closed the GST account of one of the appellant’s suppliers retroactive to June 30, 2001. ... Pentney Deputy Attorney General of Canada Ottawa, Canada ...
TCC
Joel Theatrical Rigging Contractors (1980) Ltd. v. The Queen, 2017 TCC 6 (Informal Procedure)
Louie produced four patents, [8] which were published on December 7, 1999, May 10, 2005, November 23, 2005 and September 27, 2007 respectively. ... The second requirement has five stages, the fourth and fifth of which are: • the formulation of a hypothesis or hypotheses designed to reduce or eliminate the technical uncertainty; and • the methodical and systematic testing of the hypotheses. ... In particular, the persons conducting the experiments went through a series of alterations and adjustments, including: a) removing the chain from the sprocket controlling the cable drum and removing the limit switch, b) removing the entire sprocket assembly from the limit switch, c) removing the cable drum from the limit switch, and d) removing the retaining bolts and replacing them with a hand-crank system. ...
TCC
Montana Reclaimed Lumber Co. v. The Queen, 2018 TCC 51
Pecora started with the Appellant in 2005 and is the brother-in-law of the founder of the Appellant. [5] Mr. ... The Queen, 2005 FCA 104 at paragraph 35. The Appellant admitted in its Notice of Appeal that it might be possible with enough time and effort to determine the origin of the wood. ... APPENDIX B CITATION: 2018 TCC 51 COURT FILE NO.: 2014-3418(SLP)G STYLE OF CAUSE: MONTANA RECLAIMED LUMBER CO. v. ...