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TCC

Zhao v. The Queen, 2015 DTC 1128 [at at 809], 2015 TCC 124 (Informal Procedure)

The Queen, 2010 TCC 483, the Court considered that the words of the Act clearly contemplated or required that there be a "new work location" for a taxpayer to qualify for the moving expenses deduction. ...
TCC

Keating v. The Queen, 2005 DTC 743, 2005 TCC 296 (Informal Procedure)

The Queen, 2003 DTC 5115 set out a number of factors to be considered in determining whether a debt is properly determined by a taxpayer to be a bad debt. ...
TCC

Adams v. The Queen, 96 DTC 1733, [1996] 3 CTC 2585 (TCC) (Informal Procedure)

On the basis of these authorities, even though on the face of the judgment of the earlier decision it is not obvious that the precise points now put in issue were specifically put to or considered by the judge in the prior proceeding, if they were essential to the determination reached by him a later court cannot retry the issue. ...
TCC

830480 Alberta Inc. v. The Queen, 2013 DTC 1027 [at at 132], 2012 TCC 424

Choudhry offered no evidence to explain how the mistake could be considered objectively reasonable. ...
TCC

Stepanoff v. The Queen, 2006 DTC 2260, 2006 TCC 67, aff'd 2007 DTC 5159, 2007 FCA 40

Following any such request, the parties shall review the Minimum Fee for such CyberPlan Software with a view to fixing the Minimum Fee at 25% of the market value of the licences being granted.... [7]      Clause 4.02 outlines what events would be considered a default under the license agreement, including the non-payment of the license fees or the advances on the license fees. ...
TCC

Klanten Farms Ltd. v. The Queen, 2007 DTC 1095, 2007 TCC 348

Therefore, even if “maintaining a land base” could be considered to be a use of property within the meaning of paragraph 44(5)(a.1), as submitted by the Appellant, this use of the Smokey River property would not have been the same as or similar to any use made by the Appellant of the Bowden property ...
TCC

Walsh v. The Queen, 2008 DTC 3897, 2008 TCC 282

I do believe, however, that this is where subsection 152(9) needs to be considered. ...
TCC

Brisson v. The Queen, 2013 DTC 1197 [at 1052], 2013 TCC 235

In DeCosta v The Queen, 2005 TCC 545 he stated:   11 In drawing the line between "ordinary" negligence or neglect and "gross" negligence a number of factors have to be considered. ...
TCC

Capilano International Inc. v. The Queen, 95 DTC 915, [1996] 1 CTC 2254 (TCC)

Any standby period occurring after commencement of operations in Jordan will be considered an operations period insofar as surcharge computations are concerned. ...
TCC

Lavigne v. The Queen, 2014 DTC 1018 [at at 2615], 2013 TCC 308 (Informal Procedure)

In those cases, Rogers considered these expenses were unnecessary, unjustified or unreasonable ...

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