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TCC

Big Bad Voodoo Daddy v. The Queen, 2011 DTC 1173 [at at 955], 2011 TCC 226 (Informal Procedure)

Benny considered the additional expenses claimed as clearly not reasonable in the circumstances ...
TCC

Tesainer v. The Queen, 2008 DTC 2807, 2008 TCC 101, rev'd 2009 FCA 33

The Queen, [2] Woods J. considered documentary evidence over viva voce evidence in deciding the character of a settled amount. ...
TCC

Zaugg v. The King, 2025 TCC 82

Zaugg could specifically update his mailing address for the purposes of the determination of his eligibility for the disability tax credit. [27] The facts of this case are distinguishable from those considered by Justice Wong in Pour Afkari v The Queen, 2019 TCC 173. ...
FCTD

Kaur v. Canada (Citizenship and Immigration), 2025 FC 1147

All of the documents attached to the Applicant’s various March 21, 2024 and March 24, 2024 emails, along with those emails themselves, are deemed to comprise part of the record that will be considered in that proceeding. [23] The parties proposed no question for certification, and I agree that none arises. ...
TCC

Blecha v. The King, 2025 TCC 91 (Informal Procedure)

Despite the nature of an undertaking containing hallmarks of a hobby or personal pursuit, if the venture is executed and is sufficiently businesslike in fashion, then it will be considered a source of income. ...
TCC

Lewis v. M.N.R., docket 96-1638-UI

There were many reasons why the DFO weren't considered. Q.             ... There were many reasons why the DFO weren't considered. They were considered where the QMP records did not agree. ... In fact, she admitted not having considered the Appellant's submissions. ...
FCTD

Henderson Estate v. M.N.R, 73 DTC 5471, [1973] CTC 636 (FCTD), aff'd 75 D.TC 5332, [1975] C.TC 485 (FCA)

But all these elements have an effect on the price of the shares on the stock exchange, and no doubt they were fully considered by the purchasers of the stock at the then prevailing prices. ... In Johnson’s Asbestos Corp v MNR, [1966] Ex CR 212; [1965] CTC 165; 65 DTC 5089, Jackett, P considered the meaning of the phases or activities of mining preceding the delivery of ore to the pit head. ... By a notice of assessment dated August 2, 1969 the Minister considered the aggregate net value of the assets to the value of $3,771,008.03 to be Canadian assets and succession duties in the amount of $1,703,250.88 were claimed thereon. ...
TCC

Labow v. The Queen, 2010 TCC 408, 2010 DTC 1282 [at at 3956], aff'd 2012 DTC 5001 [at 6501], 2011 FCA 305

Labow had considered that his contributions to the plan were an expenditure rather than an off-shore investment. ... Labow clearly considered the funds held in the hands of the Trustee in the Caribbean to be their funds. ...   [90]     This is all the more improbable when considered in the light of Mr.  ...
ABQB decision

R. v. Warawa, 98 DTC 6471, [1998] 1 CTC 345 (Alta. Q.B.)

It is my view that the collective acts performed on the part of Revenue Canada must be considered. ... Sinclair considered the accused to be at least a suspect. At the same time that Mr. ... Thus that particular search must be considered on the basis of being a warrantless search. ...
SCC

Friesen v. Canada, 95 DTC 5551, [1995] 3 SCR 103

The more closely a taxpayer's business or occupation is related to real estate transactions, the more likely it is that the income will be considered business income rather than capital gain.   ... This definition can cause an isolated transaction involving real estate to be considered a business transaction.  ... He first reviewed the case law which considered the definition of "business" and "adventure or concern in the nature of trade".  ...

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