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Mr Lefebvre’s last contention, that the amount received by the taxpayer was a taxable capital gain, cannot, in our opinion, be considered. ...

This is an appeal from a judgment of the Tax Court of Canada pronounced on the 1 st day of March 2000 which considered whether the respondent was entitled to claim losses incurred as a result of an investment in a fraudulent "pyramid scheme". ...

BETWEEN: WAI KEUNG TSUI Appellant and THE MINISTER OF NATIONAL REVENUE Respondent REASONS FOR JUDGMENT LINDEN J.A. [1]                Having considered the material in this matter and after listening to the arguments, we have not been persuaded that there is any reason to interfere with the Applications Judge's award of costs. [2]                The appeal will be dismissed with costs to the Crown of $500.00 inclusive of tax and disbursements.      ...

All of these factors were properly considered by the Tax Court Judge in arriving at his decision not to interfere with the earlier decision of the Court. ...

Where the relevant facts as of the time of the purchase are considered together with the subsequent events and the affirmations of the appellant’s shareholders, it is not realistic to conclude that the only possibility that motivated the acquisition was the ultimate creation and retention of a very substantial housing development. ...

When, as in the present case, different parts of a same building are permanently used for what is considered to be two different purposes, the most important factor in determining the purpose for which the building is primarily used is the amount of space in the building that is used for each one of those two purposes. ... This may be true, but that difference in costs is not, in my view, sufficient to outweigh the factor that I have just considered. ...

I have considered whether Mr. Swift could have been named as a party to these proceedings on the basis of Rule 303. ... I have also considered whether this is an appropriate case to grant Mr. ...

We think the Tribunal must be taken to have considered the whole of Note 1(a) and simply to have thought the first part to be irrelevant. ... The Tribunal was clearly aware of the whole paragraph and if it had thought the first part to be relevant it would have considered it specifically. ...

   [4]                        The leading case on the criteria to be considered when deciding whether to grant an extension of time for launching an appeal are set out in this Court’s decision in Pharmascience v. ... The factors to be considered are conveniently summarized in Karon Resources Inc. v. ...

  [8]                Mr Roper also argued that the Judge should have considered the Court’s broad discretion to issue an Order that was just, despite his failure to comply with an Order of the Court. In particular, he said, the Judge should have considered whether dismissing the appeal was necessary for ensuring a just result. ...