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[6]                I am bound by that finding and do not propose to review the jurisprudence that the Federal Court of Appeal already considered in arriving at that conclusion ...

[10]            Having considered all the evidence, the Court is satisfied that the Minister has met the test outlined in the Income Tax Act. [11]            In addition, the debtors have not convinced the Court that the Minister did not meet his obligation of reasonable disclosure. [12]            Consequently, the debtors’ application is dismissed with costs and the jeopardy collection order is upheld.  ...

. […] 2) Le délinquant qui croit que les renseignements auxquels il a eu accès en vertu du paragraphe 23(2) sont erronés ou incomplets peut demander que le Service en effectue la correction; lorsque la demande est refusée, le Service doit faire mention des corrections qui ont été demandées mais non effectuées. [4]                In this case, the applicant claims to have not followed the procedure set out in subsection 24(2) of the Act. [5]                However, the applicant should not have more rights than another inmate who is pursuing remedies under the Act, so the applicant cannot proceed directly through an action. [6]                Furthermore, if the applicant requested that information in his record be corrected, and he is not satisfied with the reply he received, he had to have this Court conduct a judicial review of that reply, which he did not do. [7]                Indeed, as extensively explained by the respondent, only an application for judicial review can determine the lawfulness of this reply or decision. [8]                Here, the applicant cannot collaterally attack a decision by a tribunal by means of an action for damages to avoid parceling out the review of the lawfulness of decisions by federal bodies. [9]                Furthermore, even if we considered, as claimed by the applicant in his motion record against the motion under review, that the central premise of his action for damages is not founded on the decision to deny the withdrawal of a statement obtained from the applicant, but rather that the applicant is seeking to properly bring an action against respondent Séguin for false and malicious allegations, this action, despite the wording of paragraph 17(5)(b) of the Federal Courts Act, R.S.C., 1985, c. ...

”   [3]                I have considered the submissions of the parties and have noted that the applicable sections of the legislation do, in certain situations, provide for the release of taxpayer information and personal information. ...

All previous applications have found no impropriety and were considered on a full record. ...

She considered that she was entitled to costs under Column V of Tariff B, given the shocking nature of the decision currently under review and the delay in rendering the decision. ...

BESSELT                                                                                                  Respondent CONSIDERED AT TORONTO, ONTARIO PURSUANT TO RULE 369 AMENDED REASONS FOR ORDER AND ORDER BY:                                GILES A.S.P. ...

Accordingly, unless the Tax Court Judge applied the relevant principles unreasonably, or, in light of the evidence before him, committed some palpable and overriding error in making findings of fact, this Court will not intervene. [5]                Having considered the evidence as a whole, the Judge concluded (at para. 18) that the renovations were so substantial in nature that "the house was virtually rebuilt and resulted in a new capital asset" and, consequently, the cost of the work should be characterized as being of a capital nature. ...

., [1962] S.C.R. 65, and exclude its application and the principles derived from it, namely that the spouses are, it is true, co-owners of the community property but for tax purposes other factors should be considered. 1 [3]      Among these factors, the Supreme Court noted the fact that the husband held all the attributes of ownership and absolute enjoyment of the property, the wife did not have the plenitude of rights ordinarily conferred by ownership, her right being dismembered, inferior, stagnant and sterile, and the plenitude of the right of ownership (that is, the jus utendi, fruendi et abutendi) only accrued on dissolution of the community ([1962] S.C.R. 65 "> Sura, at 72). [4]      In view of the nature of the ownership which under her matrimonial regime accrued to the appellant"s wife over community property, it is not possible to conclude that for tax purposes she acquired ownership of community property in the year it was purchased by her husband, who administered the community property by himself, or that she acquired the proceeds of disposition of that property within the meaning of ss. 39(1)(a) and 54(c)(i) of the Income Tax Act in the year in which it was sold by him. ...

(iii) any expense incurred by him for the purpose of determining the existence, location, extent or quality of a mineral resource in Canada including any expense incurred in the course of                      (A)      prospecting,                      (B)      carrying out geological, geophysical or geochemical surveys,                      (C)      drilling by rotary, diamond, percussion or other methods, or                      (D)      trenching, digging test pits and preliminary sampling,                  but not including                      (E)      any Canadian development expense, or                      (F)      any expense that may reasonably be considered to be related to a mine, whether or not owned by the taxpayer, that has come into production in reasonable commercial quantities or to be related to a potential or actual extension thereof ...