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TCC

Wetzel v. The Queen, docket 2000-1401-IT-I (Informal Procedure)

Second, the Respondent did not have enough consideration for the convenience of the Appellant as to where the motion should be heard. ...
TCC

Bell v. The Queen, docket 98-2804-IT-I (Informal Procedure)

This Court finds that the Minister, in these circumstances, should have given the Appellant further consideration before denying the deductibility of his further expenses. [16] This appeal is allowed on the basis that the Appellant should be reassessed only for the years 1995 and 1996. ...
TCC

Université Laval v. M.N.R., docket 1999-857-EI

(Administrative Services Only) system. [12]          The employment held by the employee constitutes insurable employment under the Unemployment Insurance Act and/or the Employment Insurance Act. [13]          The appellant's position is that the payments made to its employees under its health and disability insurance plan do not constitute insurable and contributory earnings because those payments are not made in consideration of corresponding work. ...
TCC

Mayor v. The Queen, docket 1999-3855(IT)I (Informal Procedure)

Hoping that logic will prevail over every other consideration, I thank you in advance for your attention to my objection.                                                                         ...
TCC

Gartner v. The Queen, docket 1999-4130-IT-I (Informal Procedure)

Gartner intended to and did live separate and distinct lives from each other during the periods under consideration by the Reassessments. ...
TCC

Crate v. The Queen, docket 1999-334-IT-I (Informal Procedure)

The Appellant's contention that the amounts paid by her in-laws reflected going market rates must be viewed in the context of a statement she made in a Rental Questionnaire [6] where she observed that for the years in question their rental rate was established by taking into consideration several factors including the in-laws' financial situation and the "resultant amount of disposable income they had". ...
TCC

Kingsbury v. The Queen, docket 98-3839-GST-I (Informal Procedure)

Rather, the Act contains both objective elements- embodied in the reasonable person language- and subjective elements- inherent in individual considerations like "skill" and the idea of "comparable circumstances". ...
TCC

McColl v. The Queen, docket 2000-445-IT-I (Informal Procedure)

One consideration may point so clearly that it dominates other and vaguer indications in the contrary direction. ...
TCC

Harris v. The Queen, docket 97-447-IT-I (Informal Procedure)

That evidence must be bolstered by some other evidence that has significant persuasive force of its own. [21] In McKimmon supra, the Federal Court of Appeal set out at page 6090 some considerations to be taken into account in determining if the payments are periodic support payments or capital payments. ...
TCC

Shandala v. The Queen, docket 98-2065-IT-G

They were doing their best in a difficult situation. [16] Even if I accepted the testimony of the Appellant and her husband that the property, from July 1, 1993, was held exclusively for rental (and I do not accept this allegation) they have not satisfied me as to what the fair market rental value was at that time nor the value of the land and building at that date. [17] Thus, there is no way I can come to the conclusion that a rental business, if established, would have had a reasonable expectation of profit after taking into consideration capital cost allowance nor could I calculate what the terminal loss on the building would be or the capital loss on the property. [18] The Appellant did claim a rental loss for part of the year 1994. ...

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