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Analysis and discussion [19] The Federal Court of Appeal has said that in the context of support payments and the wholly dependent person credit, the concept of set-off distracts from the real issue which is whether or not the appellant is the only parent making a child support payment. [16] [20] In Verones, the appellant paid monthly child support in an amount which represented a set-off between what he and his former spouse were each required to contribute under the Federal Child Support Guidelines. [17] Their respective Guideline incomes were referenced in the court order but only the appellant was directed to pay a support amount. [18] [21] In upholding the Tax Court’s dismissal, the Court considered the Supreme Court of Canada’s statement that the underlying principle behind the Guidelines is that spouses have a joint financial obligation to support their children in accordance with their relative abilities to do so. [19] After determining their respective obligations to contribute under the Guidelines, one parent may be required to make child support payments to the other; however, the set-off concept does not transform the respective obligations into support payments for income tax purposes. [20] [22] In the present appeal, the separation agreement only requires Mr. ...

The balance sheet of Stewart & Morrison Inc. for 1965, Exhibit 7, shows “Stockholders Equity” as follows: Represented By: Loans and/or Capital $65,000.00 Less: Net Loss for period ended June 30, 1965 54,528.23* $10,471.77 An accompanying covering letter from Katz & Company states that the total capital and loans are to be considered as $1,000 capital stock and $64,000 corporate loans. ...

In so far as the substitutes are concerned, whether considered jointly or severally, I think that any anticipated opening, far from being disadvantageous to them, was for their benefit. ...

The excess was considered shareholder advances. [25] She stated she had full control over the Appellant’s bank accounts and gave herself money when it made sense and when they needed it. ...

This was reasonable notwithstanding the Board’s description of section 32 as providing a presumption that provincial limitation periods apply, a statement about which I have considerable doubt. [16] Finally, the applicant submits, the Board failed to reasonably justify its departure from its own decision in Dansou and from Markevich when it concluded the cause of action arose “otherwise than in a province”: Applicant’s Memorandum of Fact and Law at para. 25. [17] Over several paragraphs in its reasons, the Board discussed both cases and explained why it considered them distinguishable and not determinative of the question before it: see reasons at paras. 76-89. ...

It is understandable why the objections and correspondence submitted by the appellant in 2019 were considered by the Minister under administrative relief, because there were no remaining avenues by then. [26] Unfortunately, neither the Court nor the Minister has the power to extend the time to object where a person does not make their request within the one year permitted by the Act. [32] Based on the timeline of events, the appellant took his various steps after the time limits had passed and as a result, there is no power or discretion left for the Minister or the Court to exercise under the law. ...

The Court (at para 13) considered whether a similar rule in the Federal Court Rules could be used to extend a limitation period in the Customs Act and held that it could not: Furthermore, it seems clear to me on a plain reading of Rules 6 and 302 that they have no application to the case at hand. ...

While I acknowledge that the resulting subsection 163(1) penalty is harsh, that is a matter for Parliament to address. [24]         In reaching this conclusion, I have considered the cases provided by counsel in the Joint Book of Authorities, including the decision of the Tax Court of Canada in Galachiuk v. ...

So, each amount of support payable under an agreement or order that is not specifically identified as being solely for spousal support, is considered to be child support. [27] Element C is the total amounts each of which is a support amount paid by the taxpayer to the particular person after 1996 and is deductible in computing the taxpayer’s income for a preceding taxation year. ...

The same document, as well as the CRA officer’s Second Review Report, list all the art sold (and at what price) in their summaries of evidence, indicating that the officer had indeed considered the amount claimed: CRA officer’s notes, CTR at 27. ...