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The Applicant also earned $2,248.00 in connection with her participation in a JCP, which was reported on a T4A “Statement of Pension, Retirement, Annuity and Other Income” slip in Box 28 issued by Arrow & Slocan Lakes Community Services [ASLCS]. [6] The Applicant received the CERB between March 15, 2020 and September 26, 2020, and the CRB between September 27, 2020 and April 24, 2021. [7] On June 6, 2024, in Fournier v Canada (Attorney General), 2024 FC 859 [Fournier], this Court allowed the Applicant’s second application for judicial review, quashed the prior decisions of the CRA, and returned the matters to a different CRA officer for redetermination. ... Where the new evidence brings to the attention of the reviewing court procedural defects not found in the evidentiary record of the decision maker; and [17] After a careful review of the record before the Court, I agree with the Respondent that Exhibits 2 and 4, not only postdate the Decisions, but go directly to the core issue that was before the Fourth Reviewer, namely, determining the nature of the payments made to the Applicant in connection with her participation in the JCP. ...

The agreement, however, gave to the purchaser the privilege of cancelling the same at its sole option in the event that it had not been successful in getting certain approvals or authority in connection with the said lands with the Ontario Municipal Board prior to April 30, 1979. ...

In connection with the audit, the Minister sought information from the three parties. ...

., [1994] 1 C.T.C. 199, 94 D.T.C. 6166 (F.C.T.D.). maintained in connection with a business carried on for profit or with a reasonable expectation of profit. ...

The question is not that, but whether the collateral legislative action in connection with the Income Tax Act has the effect of amending the 1956 statute. ...

Pursuant to subsection 178(2) of the Income Tax Act the Minister shall pay all reasonable costs of the taxpayer in connection with this appeal in which the amount of tax involved is less than $2500. ...

But where there is credible evidence, as there is here, of actual use and enjoyment by the taxpayer of the contiguous land in connection with her house, and such use and enjoyment is not of an exaggerated or unnatural sort, a great deal of weight must be attached to it in assessing whether such use can be reasonably regarded as contributing to the taxpayer's use and enjoyment of his residence. [1] It is not for the officials of the Department of National Revenue, nor for the courts, to be the arbiters of lifestyles chosen by taxpayers. ...

The Minister of National Revenue shall, pursuant to subsection 178(2) of the Income Tax Act, pay all reasonable and proper costs of the defendant in connection with this appeal (see The Queen v Creamer, [1977] CTC 20; 77 DTC 5025). ...

This is borne out by the subsequent event that upon the completion of the plant it severed its connection with the plaintiff. ...

I am therefore obliged to virtue of subsection 178(2) to order the Minister to pay all reasonable and proper costs of the taxpayer in connection with the appeal and I do so. ...