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In any case, at the death of Mr Dontigny his immovables became “vested indefeasibly in his spouse”, and consequently paragraph 7(1)(a) authorizes the deduction claimed even if the will creates a substitution: (a) Subsection 7(2) stipulates that a superannuation benefit payable to the spouse of a deceased, in respect of the death of the deceased, “subject to a provision that such benefit ceases to be payable to such spouse if he remarries, shall not, by reason only of such provision, be considered not to be vested indefeasibly in him”. ...

Payment for space reserved in a newspaper by an advertiser is, in respondent’s submission, payment for services rendered, and a printer’s income from this source cannot be considered as income from the sale of manufactured and processed goods within the meaning of section 40A of the Act. ...

Apparently also the receipt of the 5% of the capital stock of the appellant at the total nominal price of $5, pursuant to the letter of agreement (Exhibit 7), which is interrelated to the agreement (Exhibit 8), was and has always been considered by Traders Realty Limited as a capital receipt. ...

This particular subsection was also considered in the case of Hart J. ...

Unlike the situation with respect to prejudgment interest, the plaintiff cannot be considered to have delayed in seeking satisfaction of judgment since the day it was delivered. ...

</p>] Associate Chief Justice Jerome wrote at page 727: In Satellite Earth, MacKay J. reviewed the factors to be considered by a court on a s. 225.2(8) review of a jeopardy collection order. ...

The Applicant was asked, but unable to provide any verification for the said deposit in the Updated Bank Statements. [31] As the Respondent submits, the Applicant bears the burden of showing that there are sufficiently serious shortcomings in the Decisions such that they cannot be said to exhibit the requisite degree of justification, transparency, and intelligibility: Aryan v Canada (Attorney General), 2022 FC 139 at para 16; Flock v Canada (Attorney General), 2022 FC 305 at para 15. [32] The Applicant’s primary argument is that the CRA agent should have considered the 2019 NOR, without any supporting documents such as invoices, as evidence that he met the minimum income requirement. ...

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. ...