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TCC

Taylor v. The Queen, docket 1999-2778-IT-I (Informal Procedure)

Notwithstanding subsections (4), (4.1) and (5), where the result of an assessment or a decision on an appeal is to change a particular balance of a taxpayer for a particular taxation year, the Minister may, or where the taxpayer so requests in writing, shall, before the later of the expiration of the normal reassessment period in respect of a subsequent taxation year and the end of the day that is one year after the day on which all rights of objection and appeal expire or are determined in respect of the particular year, reassess the tax, interest or penalties payable, or redetermine an amount deemed to have been paid or to have been an overpayment, under this Part by the taxpayer in respect of the subsequent taxation year, but only to the extent that the reassessment or redetermination can reasonably be considered to relate to the change in the particular balance of the taxpayer for the particular year. ...
TCC

Trainor v. The Queen, docket 98-1729-IT-I (Informal Procedure)

I also see nothing that necessarily leads to the conclusion that it is only the first 15 days that are considered. ...
TCC

Simard v. The Queen, docket 98-2084-IT-I (Informal Procedure)

In view of the absence of any supporting evidence or of even the most basic accounting, the total amount of the sums received periodically clearly cannot be considered as reimbursements or advances. ...
TCC

Grzywnowicz v. The Queen, docket 2000-173-IT-I (Informal Procedure)

The following criteria should be considered: the profit and loss experience in past years, the taxpayer's training, the taxpayer's intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...
TCC

Fantini v. The Queen, docket 96-3863-IT-I (Informal Procedure)

The Queen, 83 DTC 5365 where the effect of a deeming provision in a Saskatchewan statute was considered in relation to when an estate became indefeasibly vested. ...
TCC

Osovski v. The Queen, docket 2000-2404-IT-APP

This is why he is seeking to obtain an order extending the time within which he may institute an appeal against the determination by the Minister. [3]            The important dates to be considered in this application are the following. ...
TCC

Jacks v. The Queen, docket 1999-5125-IT-I (Informal Procedure)

Music which is not "mainstream" today may be so considered tomorrow. ...
TCC

Tardif v. The Queen, docket 1999-3920-IT-I (Informal Procedure)

The vendor declares that the immovables being sold are immovables mainly and completely occupied for residential purposes, that she has performed no major renovations and has not claimed and will not claim any input tax credit in respect of the purchase of or improvements to the said immovables.... [9]            In analyzing the documents and explanations submitted, the Minister only considered expenditures of approximately $3,500 as being valid; all the other expenses were disallowed on the ground that invoices were either non-existent or incomplete or debatable as to their content, being addressed to the "Almex" company. ...
TCC

Lessard v. The Queen, docket 2000-1732-GST-I (Informal Procedure)

The vendor, represented by her notary, considered that the tax status of the building should be based on use by the then owner (the vendor); as the vendor did not use the building "primarily as a place of residence", "the whole " thereof could not therefore qualify as a "residential complex" as provided for in paragraph (c) of the definition of "residential complex" found in subsection 123(1) of the Excise Tax Act (ETA). ...
TCC

Poisson v. The Queen, docket 1999-4221(IT)I (Informal Procedure)

In other words, do the payments meet the requirements established by the Act and the case law to be considered as support (alimony) or periodic payments? ...

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