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TCC
Charron v. R., [1998] 2 C.T.C. 2240
Conclusion 24 The appeal is allowed with costs on the basis that the sum of $23,593 should be considered in computing the UCC. ...
TCC
Zator v. R., [1997] 3 C.T.C. 3094
Suspicious circumstances, therefore, will more often lead to closer scrutiny than those that are in no way suspect. 11 The courts have further considered another test as to whether there is a carrying-on of business. ...
TCC
Sponagle v. R., [1997] 3 C.T.C. 2053
That as long as the children are attending a post-secondary institute or attending a vocational school in pursuit of a diploma or under-graduate degree, they will be considered to be children of the marriage. 6 Commencing January 15, 1988 Barry made payments in the amount of $125.00 in accordance with the Amended Order. ...
TCC
Callahan v. The King, 2023 TCC 172 (Informal Procedure)
It is well established that service or delivery of the notice of objection on the Chief of Appeals in accordance with subsection 165(2) is a necessary first step, failing which, this Court cannot hear the appeal. [27] Even if the Appellant’s letters to the CRA were considered a valid notice of objection, this Court would still not have jurisdiction to judicially review the exercise of the Minister’s discretionary decision not to waive the penalties and interest at issue. ...
TCC
Ibrahim v. Canada (Employment and Social Development), 2021 TCC 64
The amounts are included in income for GIS income determination purposes. [18] In the unlikely case that the amounts were not considered a “pension,” it is likely that the amounts are caught under section 3 of the ITA alone and would be included in the GSI income determination. ...
TCC
McLean Estate v. The King, 2022 TCC 150 (Informal Procedure)
Pansegrau Counsel for the Respondent: Katherine Matthews ORDER WHEREAS after hearing opening submissions and initial testimony of the Appellant’s personal representative and executor, Respondent’s counsel moved to quash the appeal because of the lack of jurisdiction to hear the appeal; AND WHEREAS the Court considered such motion, recessed and reconvened to render oral reasons for decision; NOW THEREFORE THIS COURT ORDERS THAT: The Respondent’s motion is granted, without costs; and, The appeal is quashed because the Court lacks jurisdiction to hear an appeal to waive interest on an assessment. ...
TCC
Qari Mohd Saleem v. Minister of National Revenue, [1984] CTC 2660, [1984] DTC 1579
The following criteria should be considered: the profit and loss experience in past years, the taxpayer’s training, the taxpayer’s intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...
TCC
David R Meakes v. Minister of National Revenue, [1984] CTC 2781, [1984] DTC 1670
The following criteria should be considered: the profit and loss experience in past years, the taxpayer’s training, the taxpayer’s intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...
TCC
Simon Wong v. Her Majesty the Queen, [1996] 1 CTC 2655 (Informal Procedure)
He made the necessary decisions as a 40 per cent owner of Hifi and he was the one who personally guaranteed the HiFi loan from the C.I.B.C. and that he considered himself the beneficial owner of the shares in HiFi. ...
TCC
Watts v. The King, 2024 TCC 100
The constitutional legitimacy of the search at issue in the First Motion had been previously considered and confirmed twice by the Ontario Superior Court of Justice, [1] once by the Ontario Court of Appeal, [2] in a leave application before the Supreme Court of Canada, [3] and in the Federal Court. [4] While those cases were brought by the Appellant’s husband, it was the same search, the same warrant, and essentially the same legal challenge as in the Appellant’s First Motion. [5] [8] Ultimately, all three motions were unsuccessful. ...