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TCC

Snow v. The Queen, 2012 DTC 1116 [at at 3087], 2012 TCC 78 (Informal Procedure)

As clarified in written submissions received from the respondent following the hearing, these amounts do not have to be considered separately because they are part of the child tax benefit in section 122.61 of the Act.   ...
TCC

GMC Distribution Ltd. v. The Queen, 2012 TCC 262

the above dates shall be considered strict time limits. In the event of the Appellants’ non-compliance with such time limits, the Respondent shall be free to bring a motion in writing to dismiss the appeals for the Appellants’ failure to comply with the terms of this Order.   5.       ...
TCC

Fannon v. The Queen, 2012 DTC 1007 [at at 2534], 2011 TCC 503 (Informal Procedure)

Both the purpose and the effect of the legislation must be considered in determining the appropriate comparison group or groups. ...
TCC

Shaw v. The Queen, 2013 DTC 1214 [at at 1193], 2013 TCC 256

The reimbursement of these expenses cannot be considered as conferring a benefit within the terms of the Act. ...
TCC

Constructions Marabella Inc. v. The Queen, 2012 TCC 397 (Informal Procedure)

  [25]         Fraudulent activity of this sort has been considered in a number of judgments. ...
TCC

S.E.R. Contracting Ltd. v. The Queen, 2006 DTC 2212, 2006 TCC 6 (Informal Procedure)

He considered this to be a good price, and so he accepted the offer. He and his wife conveyed lot 15, together with the unfinished house, to the Appellant on April 3, 1997 for $80,000. ...
TCC

Ganpaul v. The Queen, 2009 DTC 731, 2009 TCC 205 (Informal Procedure)

Nanthakumaran confirmed the Appellant’s testimony that upon receipt of the Notice of Confirmation, he had been called by the Appellant, puzzled about the decision and asking why his information had not been considered. ...
TCC

Tokarski v. The Queen, 2012 DTC 1138 [at at 3213], 2012 TCC 115 (Informal Procedure)

  [28]     That is to say, it is impossible to say what Parliament intended in respect of travel expenses in a case like this except to note that if fiscal issues were being considered, Parliament might well have wanted to allow the travel expense in this case. ...
TCC

Montplaisir Ltée v. MNR, 92 DTC 2317, [1992] 2 CTC 2700 (TCC), aff'd 96 DTC 6557 (FCTD). aff'd 2001 DTC 5366 (FCA)

In these respects particularly, the facts of the instant appeal are distinguishable from those of the cases cited by the respondent in which the businesses carried on by the taxpayer had clearly ceased to be operated or had so been altered in the loss application years that they could not be considered as being the business carried on by the taxpayer during the loss years. ...
TCC

Janota v. The Queen, 2010 TCC 395, 2010 DTC 1268 at 3893 (Informal Procedure)

Many of the projects were to simply maintain the building and should not be considered a betterment. ...

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