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FCTD
Khan v. Canada (Attorney General), 2024 FC 1840
Khan submits that the Officer should have considered equitable factors, including illness and financial hardship, when assessing his eligibility. [3] I am mindful of and commend Mr. ... Taken in their entirety, the reasons show that the Officer carefully considered the materials Mr. ... Khan was unsuccessful in demonstrating that the decision is unreasonable, he brought this application in good faith seeking to have his circumstances considered. ...
FCTD
Grant v. Minister of National Revenue, [1999] 2 CTC 103, 99 DTC 5146
.: The information before me does not demonstrate that the decision maker(s) considered all the relevant facts on which Mr. ...
FCTD
Bigelow v. The Queen, 90 DTC 6262, [1990] 1 CTC 351 (FCTD)
Justice Cattanach received and considered evidence of later years, and said (at page 375 C.T.C. ... Evidence of years other than the tax years in question has also been considered in cases where the determination relates to classifying farming activities within the second or third classes identified by Dickson, J. ... My conclusion is that under the Income Tax Act these activities must be considered as hobby farming. ...
FCTD
Cull v. The Queen, 87 DTC 5322, [1987] 2 CTC 63 (FCTD)
And at page 444 (D.T.C. 5283):...the payments made by respondent could not properly be considered as an investment in the circumstances in which they were made. ... It is, of course, obvious that a loan made by a person who is not in the business of lending money is ordinarily to be considered as an investment. It is only under quite exceptional or unusual circumstances that such an operation should be considered as a speculation. ...
FCTD
Karia v. Canada (Minister of National Revenue), 2005 DTC 5282, 2005 FC 639
" It went on to say: The circumstances of your case have been carefully considered and I regret to inform you that your request cannot be granted. ... Unfortunately, the disclosure was not considered to be voluntary since it was initiated based on the knowledge of current enforcement activities. [5] The individual taxpayer through his counsel sought an administrative review of this decision. ... Once CCRA officers learned, or believed that they had learned, that there was an "agreement with" the Peel Regional Police, that was apparently considered determinative of the matter. ...
FCTD
Fradet v. The Queen, 83 DTC 5445, [1983] CTC 424 (FCTD), aff'd 86 DTC 6411, [1986] 2 CTC 321 (FCA)
Defendant insists moreover that it is the price which was paid for the claim which must be considered. ... A debt is considered to be bad for the purposes of section 50 only when the whole amount is uncollectable or when a portion of it has been settled and the remainder is uncollectable. Where a portion of a debt can be considered uncollectable this portion is not considered to be bad for purposes of section 50 even though accounting practice may require a write-down to realizable value. ...
FCTD
Chisholm v. Canada (Customs and Revenue Agency), 2005 FC 303
I have carefully considered the facts of the case and your previous submissions as they relate to the applicable legislation. ... The case will be considered if the case was settled in favour of the taxpayer. ... Cornwell did not file a Notice of Objection to the 1991 tax year, so this option cannot be considered.... ...
FCTD
Braceland v. Revenue Canada Fairness Group Appeals, docket T-4-98
In this context, the minister"s duty to act fairly requires that the Minister give the person the opportunity to make submissions and that all evidence presented be considered. ... In addition, I have no evidence by the applicant that the respondent considered irrelevant information or considered documents which were irrelevant and was taken into consideration by the Minister in arriving at his decision. [20] The applicant contends that the interest resulted from circumstances beyond his control. ... These arguments were considered by Mr. Young in the context of the applicant"s second request for cancellation of interest. ...
FCTD
Peter Pond Holdings Ltd. v. Canada (Attorney General), 2010 FC 5
She also considered the Applicant’s submission that it was impossible for the fair market value to be determined and the withholding amount to be remitted any earlier but disagreed with this position. It is quite clear that the Minister’s delegate considered the facts of the case at hand and did not follow the administrative guideline blindly. ... The Applicant adds that none of these factors affected its ability to remit the tax and thus, should not have been considered. ...
FCTD
Island Timberlands Lp v. Canada (Foreign Affairs), 2009 FC 258
If an offer is valid and at domestic fair market value, FTEAC makes a recommendation to the Minister that the logs should be considered to be not surplus to domestic needs. ... [13] At its February 1, 2008 meeting FTEAC considered Kemp’s request. ... [27] Even if the decision was considered not to be in conformity with Notice 102, it could not be determinative of its reasonableness. ...