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TCC

Sanders v. R., [1996] 1 CTC 2617

Despite the sympathy which I feel for this family I cannot offer relief based on considerations which are not relevant under the statute. ...
TCC

Stockman v. R., [1996] 1 CTC 3001

After consideration, the Minister issued reassessments for the 1990 and 1991 taxation years which had the effect of allowing Mr. ...
TCC

Leona Obrand Kape v. Her Majesty the Queen, [1994] 2 CTC 2301

Giving consideration to all of the facts, I find that the appellant was not employed by Stephen Kape Industries Inc. and did not receive a salary or wages within the meaning of the Act from the Stephen Kape Industries Inc. ...
TCC

Armand Boisvert v. Her Majesty the Queen (Informal Procedure), [1994] 2 CTC 2312

Taking into consideration the evidence before me, the submissions and case law, although the matter is not free from doubt, I am satisfied that the better view is that the appellant has succeeded in his burden. ...
TCC

Ronel Dorneval and Célimène Bien-Aimé v. Her Majesty the Queen (Informal Procedure), [1994] 2 CTC 2381

I therefore conclude that the appellants had lived apart since May 29, 1990 and that the Minister must reassess accordingly, taking also into consideration the admissions of the appellants in respect of certain false statements made in their respective returns as mentioned above. ...
TCC

Céline Delisle v. Her Majesty the Queen, [1995] 1 CTC 2007

Ed Delisle (the "transferor") transferred cash in the amount of $10,000 (the "property") to the appellant; (c) the transferor is the son of the appellant and as such the transferor and the appellant were not dealing at arm’s length; (d) at the time of transfer, the fair market value of the consideration given by the appellant for the property was zero; (e) the aggregate of all amounts that the transferor was liable to pay under the Act in or in respect of the taxation year in which the property was transferred or any preceding taxation year was at least $26,671.18. ...
TCC

Michael C. James v. Her Majesty the Queen, [1995] 1 CTC 2626, 95 DTC 540

Analysis The consideration here is whether or not the applicant should be excluded from the time limitations otherwise imposed on him because he did not receive actual notices of the confirmation. ...
BCSC decision

Attorney General of Canada on Behalf of Her Majesty the Queen in Right of Canada as Represented by the Minister of National Revenue v. Avalon Developments Limited, Molnar Construction Limited and 942 Holdings Limited, [1994] 1 CTC 404

Before I discuss the two bases upon which the respondents challenge the validity of my order of August 9, 1993, I should mention some of the information and considerations which satisfied me that the order was justified. ...
TCC

Lucy Gagnon Ayoub v. Her Majesty the Queen, [1994] 1 CTC 2240, 93 DTC 1118

Lastly, counsel for the respondent indicated to the Court that the appellant's failure to testify at the hearing had to be taken into consideration. ...
TCC

Henri Léveillé v. Her Majesty the Queen (Informal Procedure), [1993] 2 CTC 2190

The defendant agrees to pay the plaintiff as a lump sum the amount of $25,000, to be payable as follows: — $12,500 payable on the date this agreement is signed; — $6,250 payable on the date the divorce decree is rendered; — $6,250 payable within five days of receipt of the divorce certificate; in the event that the defendant fails to make these payments on the dates scheduled, the balance shall become payable and bear interest at 12 per cent per annum from the due date; 6. in consideration hereof and on condition that the sum of $25,000 is paid, the parties give each other full and final mutual release from any claim they might make against each other; 9. as of the date of signature of this consent, the parties waive their right to any alimony, lump sum or compensatory allowance.... ...

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