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FCTD
Ernest C. Hammond v. Minister of National Revenue, [1971] CTC 663, 71 DTC 5389
Of these two objections, however, the latter no longer needs to be considered since the parties agreed at the trial that the net profit made by the appellant from racing the horse George Royal amounted to $9,083.81 in 1964, $28,543.13 in 1965 and $28,114.26 in 1966. Consequently, only the first objection raised by the appellant remains to be considered. ... He who purchases and later sells a commodity at a profit prima facie acts as a trader; for this reason, even if this transaction is an isolated one, it can very easily be considered as an “adventure or concern in the nature of trade’’. ...
FCTD
Anandarajah v. Canada (Attorney General), 2024 FC 2083
The Respondent asserts that the CRA considered the Applicant’s medical and financial hardship but reasonably found that they did not warrant relief. [16] I agree with the Respondent. [17] I first note that the Applicant’s new evidence will not be considered in this judicial review. In applications for judicial review, “only the information that was before the decision-maker can be considered” (PPSC Enterprises Limited v. ... In my view, the CRA “account[ed] for the evidence before it” and considered the “concerns raised by” the Applicant (Vavilov at paras 126, 127). ...
FCTD
Ryckman v. Canada (Attorney General), 2025 FC 1513
Ryckman did not want to answer questions by telephone the Officer gave him a deadline of August 8, 2024, to submit any information he wanted considered. ... In oral argument counsel for the Respondent asserted that this must be taken as a complete list of the documents that the Officer considered. [15] The Application Record submitted to the CRA on July 29, 2024, is not included in the list of documents and information considered by the Officer. ... Ryckman was not considered by the Officer as part of the Further Second Review. [16] The Officer’s failure to consider evidence and arguments that were central to Mr. ...
FCTD
Gerus v. Canada (Canada Revenue Agency), 2009 FC 55
Having considered all of the above I am satisfied that you were considered for all staffing actions and that you did not meet the minimum requirements for any of the staffing actions. ... Counsel submitted that the situation is analogous to that considered by Justice Dawson of this court in Anderson v. ... Only applicants who meet the pre-requisites will be considered for assessment, which is the second stage of the selection process ...
FCTD
Paranthaman v. Rogers Communication Inc., 2019 FC 916
The jurisprudence has established that the Commission is presumed to have considered the submissions and Rogers notes that the decision letter states that the Commission did so. ... There is usually no reason to question a statement that submissions have been considered. ... Paranthaman’s submissions or whether and how the Commission considered the submissions and found the explanation not to be reasonable. ...
FCTD
Matthew v. Canada (Attorney General), 2025 FC 1594
The Guidelines hold that such income will generally be considered rental income from property, but that this is not always the case. ... Accommodation sharing (e.g., AirBnB, CanadaStays): Generally, this type of income will be considered as rental income from property (line 12599/12600 of the Return). ... The range of services offered must be such that the payment could be considered as being largely put towards those services instead of a pure rental. ...
FCTD
KIK Custom Products Inc v. Canada (Border Services Agency), 2020 FC 462
Packaging imported sugar in individual serving size packets is considered to be same condition. ... The plastic bottles, caps, and labels are considered to be “same condition” when exported. ... What should be considered in assessing the reasonableness of the decision? ...
FCTD
Litmar Ltd. v. Canada (Minister of National Revenue), 2006 FC 635
There was no possibility of obtaining payment of the principal amount and no means of resolving the debt. [8] CCRA considered in detail Mr. ... Particularly, it considered that Mr. Little had knowingly allowed an outstanding balance to exist and interest to accrue on Litmar's accounts without taking quick steps to remedy this problem. [9] According to Mr. ... Little's plight and his obvious effort to deal with a difficult financial situation, the Court cannot accept his contention that his circumstances were not fully considered by CCRA. ...
FCTD
334156 Alberta Ltd. v. Canada (Minister of National Revenue), 2006 FC 1133
Under the VDP Policy, a disclosure must be considered voluntary in order to be considered as a valid voluntary disclosure. ... It is argued, however, that knowledge of enforcement activity must necessarily be considered in respect of specific taxation years. ... [12] The decision-maker swears that: I specifically considered the Applicant’s submission that Mr. ...
FCTD
Smith v. Canada Revenue Agency, 2009 FC 694
The decision and the issues [12] In said letter, it is indicated that: I have carefully considered all of the information available to me including the original request to determine if the Taxpayer Relief Provisions apply. ... Also, it must be considered that when the Fairness Committee considered the Applicant’s request it had before it not only the summary of facts but also the Applicant’s letter of August 27, 2008 and the documentation pertaining to the first review. ... What is more, he is presumed to have considered all of the evidence before him (Woolaston v. ...