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He said that it was his practise in dealing with parents of children he examined to mask the true nature of the problem identified because of what he considered potential harm. ...

. — No Canadian cases have yet considered the deemed disposition provisions of subsection 70(5). ...

Counsel for the respondent explained that he had decided not to call him because he considered the evidence already submitted to be sufficiently persuasive. ...

All relevant information from a variety of sources was considered. In this case, there was a material discrepancy between reported income and income assessed. ...

The Appellants’ position is that the company should be considered to be situate on the Reserve because its boats are docked as close to the Reserve as is possible (there being no dock available on the Reserve itself), the fishing takes place from a port close to the Reserve, and the company has an office on the Reserve, where it keeps at least some of its corporate records and does some of its business. ...

The Appellants’ position is that the company should be considered to be situate on the Reserve because its boats are docked as close to the Reserve as is possible (there being no dock available on the Reserve itself), the fishing takes place from a port close to the Reserve, and the company has an office on the Reserve, where it keeps at least some of its corporate records and does some of its business. ...

While the comparables method may be considered ideal, it must be understood that the comparables are always subjective and imperfect in terms of both quantity and quality. ...

In determining entitlement to the Canada Emergency Response Benefit, the Minister expressly considered what qualifies as income for the purposes of the benefit, and recognized that common-sense approach that amounts paid by a corporation to its owner manager could include non-eligible dividends. ...

Moreover, where a penalty is imposed under subsection 163(2) although a civil standard of proof is required, if a taxpayer's conduct is consistent with two viable and reasonable hypotheses, one justifying the penalty and one not, the benefit of the doubt must be given to the taxpayer and the penalty must be deleted... [94] With these cases in mind, as well as the analysis provided in Wood v. the Queen (2020) CCI 87, I do find that the gross negligence penalties were properly assessed. [95] The factors I have considered in upholding the penalty assessments are that Ms. ...

Abuse of process is applicable in various contexts and particularly in these cases. [18] The applicants agree that this motion is unusual and that the issues raised by the motion have never been considered by the Court. ...