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TCC

Pitchford v. R., [1997] 3 C.T.C. 2645

He is a transit driver. 4 In about 1991 he considered giving up his job as a transit driver in Victoria and moving to Saskatoon. ...
TCC

Leclerc v. R., [1998] 2 C.T.C. 2578

.), in which Décary J.A. for the Court indicated that in the case of expenses to repair or renovate property the purpose of the expense must be considered. ...
FCA

BMO Nesbitt Burns inc. v. Canada (National Revenue), 2023 FCA 43

It cites affidavit evidence of two of its employees on the point, and argues that the Federal Court erred in refusing, without an evidentiary basis, to recognize the consequent exposure of privileged information. [5] The Federal Court considered NBI’s evidence but found it vague and insufficient to establish that providing the unredacted Spreadsheet would reveal the privileged legal advice (see paragraphs 93 to 108 of the Federal Court’s reasons). ...
FCTD

Rojas v. Canada (Citizenship and Immigration), 2022 FC 293

Despite the numerous arguments raised by the applicants on appeal, the RAD considered the determinative issue to be the RPD’s conclusions regarding a viable IFA in Mexico. ...
EC decision

Gladys M. Mainwaring v. Minister of National Revenue, [1963] CTC 48, 63 DTC 1029

Main- waring’s evidence, in case No. 165547 [not yet reported], should be considered in toto as an inherent part of the instant one, a rather unusual suggestion properly objected to on appellant’s behalf. ...
FCA

Hull v. Canada, 2023 FCA 72

An appellate Court should only intervene if the Judge considered irrelevant factors, failed to consider relevant factors, or reached an unreasonable conclusion (see Guibord v. ...
SCC

Deputy Minister of National Revenue for Customs and Excise v. Consolidated Denison Mines Ltd. And Rio Tinto Mining Co. Of Canada Ltd., [1965] CTC 438, 65 DTC 5259

Therefore, there remains to be determined whether the rock bolt is a “ safety device and equipment for the prevention of accidents in the manufacturing or production of goods’’ (the italics are to indicate the questions left to be considered). ...
EC decision

Bert Robbins Excavating Ltd. v. Minister of National Revenue, [1966] CTC 371, 66 DTC 5269

On the authority of the Bibby case, [1945] 1 All E.R. 667, the share held by William Jager in trust is to be considered as being held by him and enquiry is not to be made as to the beneficial ownership thereof. ...
EC decision

In the Matter of the Income Tax Act and Walter Herbert Biggs, [1955] CTC 74, 55 DTC 1061

If considered necessary, permitting the applicant to cross- examine Douglas Hamilton McAlpine on his affidavit sworn herein on the 20th day of May, 1954, and enlarging this application pending the completion of such cross-examination, or for such further or other order as the nature of this application may require. ...
EC decision

Noralta Hotel Limited v. Minister of National Revenue, [1954] CTC 167, 54 DTC 1079

In reply to its objections to the assessments he notified it as follows: “The Honourable the Minister of National Revenue having reconsidered the assessments and having considered the facts and reasons set forth in the Notices of Objection hereby confirms the said assessments as having been made in accordance with the provisions of the Act and in particular on the ground that for the purposes of paragraph (a) of subsection (1) of section 11 of the Act and The Income Tax Regulations made thereunder, of the assets acquired by the taxpayer from St. ...

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