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FCA

Lavoie v. Canada, 2010 FCA 266

  [5]                In finding the payments to be income from a source the Judge considered and rejected the appellant's argument that the payments were a windfall.  ...
FCA

3234339 Canada Inc. v. Canada (Minister of National Revenue), 2006 FCA 308

  [10]            Contrary to the appellant’s counsel, I do not believe however that, based on the workers’ failure to intervene regarding their status, the judge inferred that the workers considered themselves to be employees or that their silence was an expression of their intention with regard to the legal status of their employment. ...
FCA

Venneri v. Canada, 2006 FCA 165

  [2]                First of all, in detailed and meticulous reasons in support of the impugned conclusions, the judge ruled that the loss claimed by the appellant could not be considered a business investment loss within the meaning of paragraph 39(1)(c) of the Income Tax Act (“Act”). ...
FCA

St-Onge v. Canada (Attorney General), 2006 FCA 109

)   [6]                To reach this finding of fact, the judge considered that the appellants did not testify, did not have the so-called third director testify, and simply submitted documentary evidence concerning the allocation of the company’s shares among the three shareholders, that is, themselves and Jean-Claude Leblanc ...
FCA

Canada (Customs and Revenue Agency) v. Black & Decker Canada Inc., 2005 FCA 384

They incorporate a fuse, and a plastic housing fitted to the batteries and designed to enable the power pack to interface physically and electrically with the tools to which they provide power. [5]                The CITT considered that the fuse and the plastic housing distinguished the items in issue from the description in the explanatory note to heading 8507. ...
FCA

Stickle v. Canada, 2005 FCA 307

It has been considered in the disposition of Mr. Stickle's motion. [10]            Along the same lines, Mr. ...
FCA

Redeemer Foundation v. Canada (Minister of National Revenue), 2005 FCA 138

However, the likelihood of wasted time and effort generally is not considered irreparable harm. ...
FCA

Gagnon v. Canada (Minister of National Revenue), 2003 FCA 444

The judge considered this evidence and drew the inferences and conclusions that supported his ultimate finding on whether the employment was insurable. [8]                For these reasons the application for judicial review will be dismissed with costs.                 ...
FCA

R. v. Sinclair, 2003 FCA 348

It is apparent from his reasons that Judge Bowie considered on its merits the constitutional argument that counsel intended to raise on behalf of Ms. ...
FCA

Rose v. Canada, 2003 FCA 12

Nor are the bank statements, considered with Mr. Rose's affidavit, capable of establishing that the assessment under appeal is incorrect. [5]                 In our view, the decision of the Tax Court Judge is sound, based on the evidence before him. ...

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