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TCC

Lefebvre v. The Queen, 2008 TCC 395 (Informal Procedure)

The bishops, t aking into consideration the needs of the Church ' s mission and the person's qualifications (suitability, charisms and formation), issue a mandate describing the pastoral ministry that the person is assigned, and setting out the duration of the person's mandate, which is normally a few years. ...
TCC

Nowoczin v. The Queen, 2007 TCC 275

That, in addition to consideration of the taxpayer's whole course of conduct while in possession of the asset, is what in the end generally influences the finding of the Court ...
TCC

Boubard v. The Queen, 2008 TCC 133

These factors should then be analyzed to determine what weight they should be given in identifying the location of the property, in light of three considerations: (1) the purpose of the exemption under the Indian Act; (2) the type of property in question; and (3) the nature of the taxation of that property. ...
TCC

Coady v. The Queen, 2006 TCC 153

As well, consideration was given to resurrecting and developing the "Christmas tree farm" which existed on a substantial portion of the property. [17]     It was further submitted that the evidence does not point to resale of the property as having been an operating motivation. ...
TCC

Raby c. La Reine, 2006 TCC 406 (Informal Procedure)

The answers that they provided on cross-examination are particularly telling on this point. [40]     It is important to add a comment about a particular consideration that Mr. ...
TCC

Cheung v. The Queen, 2005 TCC 83 (Informal Procedure)

I should have thought that the earlier estimates would likely be more accurate. [21]     With respect to the use of StatsCan numbers, Judge Bowman went on to note that he was not prepared to make any adjustment in respect of the personal expenditures because, "unreliable as the StatsCan figures may be they at least represent the Minister's assumptions that it was the appellant's onus to demolish". [22]     The category of personal expenditures is important in any consideration of the reliability of a net worth assessment. ...
TCC

2530-8552 Québec Inc. c. M.R.N., 2005 TCC 133

Her version was essentially deemed a web of lies. [78]     The case of Diane Delisle was prejudiced by deep suspicions about the truth of her allegations; although their suspicions may have been somewhat legitimate considering the numerous discrepancies, she had the right to an objective consideration of the facts. [79]     I noted that the person who reviewed her case in a way assumed, after finding certain inconsistencies in the explanations provided, that Diane Delisle lied from start to finish. [80]     The manner in which auditors and investigators responsible for the cases dealt with Diane Delisle's case showed a marked prejudice against her; in fact, after finding some contradictions, that could however be explained by the time elapsed, they quickly concluded that Mr. ...
TCC

Tracy Willcott o/a Sandalwood Esthetics v. M.N.R., 2005 TCC 428

At paragraph 15 of her reasons, Justice Woods stated: [15]       This issue deserves more consideration than is possible in written submissions. ...
TCC

Venneri v. The Queen, 2005 TCC 329

One of those is where one wishes to show "that a notarial deed does not state the true price, or the actual consideration." ...
TCC

Naghash v. M.N.R., 2005 TCC 694

None of those considerations apply here. A characterization in accord with a declaration of the status of a Fellow receiving funding pursuant to a specific PDF and expressed clearly by U of A ‑  inter alia, on its website- is reasonable, particularly when the overall circumstances support that characterization and subsequent conduct of the parties is confirmatory ...

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