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TCC

Mpamugo v. The Queen, 2016 TCC 215

The Queen (FCA) 1991 CarswellNat 520 [5]           McGowan v. The Queen (FCA) 1995 CarswellNat 381 in obiter at para 19 [6]           Schafer (FCA) [7]           2011 TCC 39, at para 15 [8]           2016 TCC 102 [9]           2016 TCC 73 [10]          Carcone; Central Springs Ltd. v. ... The Queen 2016 FCA 68 [13]          Affidavit of Mr. Mpamugo dated December 29, 2015, para 3 [14]          On cross-examination, Mr. ... His evasiveness on this matter hurt his credibility. [17]          Exhibit R-8 [18]          Exhibit R-2, Tab 2B [19]          Exhibit R-11 [20]          Exhibits R-6 and R-7 [21]          Exhibit R-9 [22]          Exhibit R-4 [23]          I find that he was being held pending bail from November 5-17, 1999, held for a breach of his bail conditions from October 29 December 1, 2001 and in prison following his sentencing from December 9, 2004 to December 9, 2005. [24]          1995 CarswellNat 278, [1995] 1 CTC 327 [25]          Exhibit R-13 ...
TCC

Savage v. The Queen, 2017 TCC 247 (Informal Procedure)

He testified that advertising was through the use of business cards, contacts at dog shows and flyers, though he did not provide any examples of the latter. [10]          The following is a schedule of the losses over the years:   Gross business income Net business loss for the Savages 1999 $1200 $12460 2000 $1200 $12546 2001 $1200 $10604 2002 $3600 $17240 2003 $3600 $7656 2004 $3600 $6558 2005 $3600 $13442 2006 $4800 $8178 2007 $4800 $8032 2008 $1050 $29384 2009 $0 $28974 2010 $1750 $13394 2011 $2500 $21,438 2012 $1600 $15890 2013   $4000* 2014   $2500* 2015   $1900* 2016   $1600* * Unclear whether this was for each of Mr. ... Miller DATE OF JUDGMENT: December 7, 2017   APPEARANCES:   For the Appellants: The Appellants themselves Counsel for the Respondent: Hye-Won (Caroline) Ahn   COUNSEL OF RECORD: For the Appellant: Name:     Firm:   For the Respondent: Nathalie G. Drouin Deputy Attorney General of Canada Ottawa, Canada     [1]           2002 SCC 46. [2]           [1994] 1 CTC 2127. [3]           [1996] 1 CTC 2634. ...
TCC

Morrison v. The Queen, 2015 TCC 319

Directions with respect to the designation of the Appellants’ appeals as test cases in the Canadian Humanitarian Trust (“ CHT ”) and Canadian Gift Initiative (“ CGI ”) appeals; 2.         ... These appeals involve the denial by the Minister of National Revenue (the “Minister”) of charitable tax credits pursuant to subsection 118.1(3) of the Income Tax Act (the Act ”), claimed by the Appellant for donations of pharmaceuticals under tax shelter programs described as the CHT and CGI Donation Programs above, for the 2003, 2004 and 2005 taxation years respectively. ... Pentney Deputy Attorney General of Canada Ottawa, Canada     ...
TCC

7547978 Canada Inc. v. M.N.R., 2021 TCC 7

In 2005, he started his own business operating under the name Les Entreprises Darick (" Darick "). ... " Dominique Lafleur " Lafleur J. APPENDIX INCOME TAX ACT (R.S.C. 1985, C. 1, 5TH SUPP.) ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...
TCC

Demchynski v. The King, 2024 TCC 18

Is this is a pay stub? A Yes, it is. Q And this and it says it’s dated, basically, end of December 23, and it’s got year to date. So is it fair to say this would be the the last pay stub for the for the year for 2011? ... The Appellant built a family home on one of the lots, gifted some of the lots to family members and sold the remaining lots to third parties. [29] In 2005, he sold four of the lots to third parties for consideration of $74,000. ...
TCC

CHR Investment Corporation v. The Queen, 2020 TCC 17

The Appellant had utilized these tax attributes to reduce its income for each of those five taxation years. [3]   In Canada Trustco, [2005] 5 C.T.C 215, the Supreme Court of Canada pronounced three requirements for application of the GAAR. ... This is an application of the “case-by-case” rule per the FCA in Lehigh Cement, supra. [18]   Costs fixed at $3,750.00 will go to the Appellant.   ... Drouin Deputy Attorney General of Canada Ottawa, Canada   ...
TCC

Rousseau c. La Reine, 2018 TCC 9 (Informal Procedure)

[OFFICIAL ENGLISH TRANSLATION]   Appeal heard on December 11, 2017, at Montréal, Quebec. ... The Queen, 2005 TCC 545, at paragraph 11; Bhatti v. The Queen, 2013 TCC 143, at paragraph 24; and McLeod v. ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...
TCC

Hot Spot Restaurant Inc. v. The Queen, 2014 TCC 318

Peter Danakas passed away in October 2005. Voula’s brother, Leo Georgopoulos and Jason’s father, Richard Weinkauf, also testified for the Appellants. ... After reviewing all of the evidence before me, I have concluded that the families received substantial payments from third parties. [47]         I have concluded that between the time of the fire at Hot Spot in 1996 and the end of 1999 Voula received $107,614 comprising the following:        Loan from her brother Leo Georgopoulos of $7,800 on November 14, 1996. [21]        Loan from her cousin Maria Damianakou of $13,000 on January 10, 1997. [22]        Loan from her brother Leo Georgopoulos of $11,000 in March 1997. [23]        Loan from her brother Leo Georgopoulos of $8,300 on January 19, 1998. [24]        Loan from her friend Kiki Tsoukala of $8,000 in February 1998. [25]        Loan from her brother Leo Georgopoulos of $15,000 in May 1999. [26]        Distribution from the estate of Voula’s parents of $44,514 [27] on July 27, 1999. [28] [48]         Peter passed away in October 2005. ... The Minister assumed that the $55,786 comprised the following:        Unreported till tape income- $29,210        Unreported other income- $7,570        Unreported bottle return receipts- $15,602        Over-claimed cost of sales expense- $3,404. [66] [83]         Further, the $29,210 of purported unreported cash register till tape income was broken down into the following categories:        Unreported house sales reported on till tapes- $1,521        Unreported till tape income missing from sales journal- $26,744        Unreported income per sales journal/till tapes compared to amounts reported- $946. [67] [84]         The Federal Court of Appeal noted the following in Newmont Canada Corporation v. ...
TCC

Hull v. The Queen, 2021 TCC 87

The Queen, 2021 TCC 87 Docket: 2015-2187(IT)G BETWEEN: JEFFREY HULL, Appellant, and HER MAJESTY THE QUEEN, Respondent.     ... D’Arcy” D’Arcy J.   CITATION: 2021 TCC 87 COURT FILE NO.: 2015-2187(IT)G STYLE OF CAUSE: JEFFREY HULL v. ... Christina Tari   Firm: Tari Law Toronto, Ontario For the Respondent: François Daigle Deputy Attorney General of Canada Ottawa, Canada   ...
TCC

Poopathie Company Ltd. v. The Queen, 2006 TCC 195 (Informal Procedure)

Nadarajah work long hours to run a viable business. [3]      There are two issues. ...           [24]     I now turn to an issue dealing with amounts withdrawn from Mr. ... CITATION: 2006TCC195 COURT FILE NO.: 2004-4439(IT)I STYLE OF CAUSE: Poopathie Company Ltd. and Her Majesty the Queen PLACE OF HEARING: Toronto, Ontario DATES OF HEARING: December 2, 2005, February 9 and 10, 2006 and March 8, 2006 REASONS FOR JUDGMENT BY: The Honourable Justice Judith Woods DATE OF JUDGMENT: March 13, 2006 APPEARANCES: Counsel for the Appellant: V. ...

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