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The Crown now appeals from that decision on the grounds that the credits issued by BASF to jobbers cannot be considered as “valid reductions” of sale price for the purpose of section 41 of the Excise Tax Act. ...

The following factors will be considered when determining whether or not the Department will cancel or waive interest or penalties: (a) whether or not the taxpayer or employer has a history of compliance with tax obligations; (b) whether or not the taxpayer or employer has knowingly allowed a balance to exist upon which arrears interest has accrued; (c) whether or not the taxpayer or employer has exercised a reasonable amount of care and has not been negligent or careless in conducting their affairs under the self-assessment system; (d) whether or not the taxpayer or employer has acted quickly to remedy any delay or omission. ...

., and WOLVERINE SUPPLIES LTD. v ATTORNEY GENERAL OF CANADA   RULE 109 MOTIONS IN WRITING CONSIDERED AT OTTAWA, ONTARIO PURSUANT TO RULE 369 OF THE FEDERAL COURTS RULES   ORDER AND REASONS: GAGNÉ A.C.J.   ...

It is my considered opinion that the evidence, on account of its nature and, unfortunately, because of the way it was adduced, does not permit me to determine an amount that could be found to be fair and not arbitrary as being the aggregate taxable value of the property of the deceased. ...

The defendant’s auditor, Mr C W Williams, testified that the advisability of operating the business with two companies was considered when the defendant was incorporated but as the defendant’s shareholders and their wives were liable to the bond companies, it was decided that this was not worth while. ...

Said subsection reads as follows: 58. (4) A reference in this Act to the part of any tax payable or tax otherwise payable that is applicable to any property passing on the death of a deceased shall be construed as a reference to that part of that tax that is proportionate to the value of that property computed as of the date of the death of the deceased or as of such other date as is specified in this Act but as though that property were distributed immediately after that date, and, for the purposes of this Act except Part Il, in determining the part of any tax payable or tax otherwise payable that is applicable to any of the property passing on the death of a deceased, where the property so passing includes (a) any property in respect of which a deduction may, in computing the aggregate taxable value of the property passing on the death of the deceased, be made under any of paragraphs (a) to (h) of subsection (1) of section 7. except paragraph (c) thereof, or (b) any property described in subparagraph (i) of paragraph (c) of subsection (1) of section 7, to the extent of such part of its value as is equal to the amount deductible under that paragraph in computing the aggregate taxable value of the property passing on the death of the deceased, no part of that tax shall be considered as applicable to the property so included. ...

When applying the reasonableness standard, it is not the role of the reviewing court to reweigh or reassess the evidence considered by the decision maker or to interfere with factual findings unless there are exceptional circumstances (Vavilov at para 125). ...

I agree. [18] In my opinion, the record shows that the officer considered all the documents Mr. ...

I have considered the parties’ agreement but in the exercise of my discretion and in the circumstances of this case, I will order payment of $250.00 to the Respondent as costs.   ...

Decision under review [12] The Applicant applied for a second review of his eligibility to the CERB (the Second-Level Review). [13] The Second-Level Review officer considered, in addition to the documentation that was before the First-Level Review officer, the documents provided by the Applicant on July 29, August 27 and October 24, 2022: (a) A copy of a notice of assessment for the 2019 taxation year; (b) A copy of a notice of assessment for the 2020 taxation year; (c) A copy of a T4 slip for the 2019 taxation year from 9260-0535 Québec Inc. for $10,648.50; (d) Twenty-five pay slips with no date from 2021; (e) Twenty-six dated pay slips for the 2021 taxation year. [14] The Second-Level Review officer reiterated the Agency’s request to obtain invoices and bank statements from 2019 in order to confirm the $10,000 of other income self-reported by the Applicant. ...