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It was his submission that the word ‘‘assets’’ in the first proviso of Section 6(1) (n) meant all the assets acquired in bulk and must be so considered by the Minister in determining whether the proviso applied and that it was not competent for him to decide that the proviso was applicable in the case of some of the acquired assets and not applicable in the case of other assets. ...

Almost all the evidence at the hearing was directed to this issue but if the appellant succeeds in its main contention its alternative one need not be considered. ...

The appellant’s auditor, William Smith, set up a set of books— Day book, Cash book and other records—which he considered adequate for the purpose of the manager of a small hotel and beverage rooms. ...

The Officer also stated that taxpayers are responsible for understanding their TFSA plans and limits and that a lack of knowledge of taxation rules cannot be considered beyond the taxpayer’s control, as information is readily available on the CRA’s website and through their General Enquiries telephone line. [13] As such, the Officer denied the Applicant’s request. ...

The Respondent submits that the Applicant has not demonstrated the CRA denied her a meaningful opportunity to provide documents. [8] Having considered the materials and the parties’ submissions, I conclude that there is no breach of procedural fairness. ...

Rather, the Applicant simply disagrees with the Officer’s determination that the Applicant’s income from Airbnb was not considered eligible income. [22] As noted in the Second Review Report, the Officer received the documents submitted by the Applicant in her request for a second review. ...

"Angela Furlanetto" Judge FEDERAL COURT SOLICITORS OF RECORD DOCKET: T-2019-22   STYLE OF CAUSE: ADEEB AHMED v CANADA REVENUE AGENCY   MOTION IN WRITING CONSIDERED AT OTTAWA, ONTARIO PURSUANT TO RULE 369 OF THE FEDERAL COURTS RULES ORDER AND REASONS: FURLANETTO J.   ...

It is well established that service or delivery of the notice of objection on the Chief of Appeals in accordance with subsection 165(2) is a necessary first step, failing which, this Court cannot hear the appeal. [27] Even if the Appellant’s letters to the CRA were considered a valid notice of objection, this Court would still not have jurisdiction to judicially review the exercise of the Minister’s discretionary decision not to waive the penalties and interest at issue. ...

Moreover, they were decided based on their particular facts and circumstances, as all of these cases must be. [21] As to Johns-Manville, the Tax Court considered it, but viewed it as inapplicable. ...

The Minister considered the request to waive interest in the amount that would not have accrued but for the reallocation. ...