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TCC

Watts v. The Queen, 2016 TCC 148

I would remind her that if that is still her intention, that needs to be attended to before the hearing date and will not be considered sufficient grounds for me as Case Management Judge to adjourn the Appellant’s hearing date another time. ...
TCC

9079-2276 Québec inc v. M.N.R., 2014 TCC 106

The mutual intention of the parties, if there is one, must also be considered, but it must be concretely reflected in the behaviour of the parties in performing the contract (Grimard, paras. 32 and 33) ...
TCC

MacKay D.D.S. v. The Queen, 2014 TCC 33

In order to accurately determine whether the result is harsh, the dentistry income for the immediately preceding taxation year and the subsequent taxation year also needs to be considered. ...
TCC

Dalle Rive v. The Queen, 2013 TCC 243

  [3]              The Crown submits that the notice of appeal has the same fatal defects that the Court considered in Cassa v The Queen, 2013 TCC 43. ...
TCC

9218-4167 Québec Inc. v. The Queen, 2013 TCC 251 (Informal Procedure)

The Queen, [5] a case where this Court considered conduct before the Notice of Appeal. ...
FCTD

742190 Ontario Inc. v. Canada (Customs and Revenue Agency), 2006 FC 1137

  [8]                The Agency’s decision not to exercise its discretion should not be disturbed unless considered to be unreasonable (Lanno v. ...
FCTD

Obonsawin v. Canada (Minister of National Revenue), docket T-1284-98

Note      The central management and control of an organization is usually considered to be exercised by the group that performs the function of a board or directors of the organization. ...
FCTD

Veale v. Canada (Minister of National Revenue), docket T-159-97

Canada (1994) 164 N.R. 60, when it considered Rules 1612 and 1613. Moreover it would be of little assistance to the Applicant because such information is not relevant. [9]      Under the Fairness Legislation each case is to be decided on its own merits in accordance with the particular circumstances of each taxpayer, whether that taxpayer is from the Penticton District Office or other districts. ...
FCTD

Cohen v. Canada (Minister of National Revenue), docket T-2727-96

The Queen, [1989] 3 F.C. 403, which we considered at some length. While the doctrine of seizure may be harsh and severe, I must remind the plaintiff that he had the right to present his case to this Court, even without retaining counsel. ...
FCTD

Canada (Minister of National Revenue) v. Piccott, 2003 FCT 217

The September 27, 2002 Order was silent as to costs therefore, only the October 16, 2002 motion can be considered. 5 units will be allowed for item #1. [6]                 Mr. ...

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