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That it did not do before November 17, 1997. [10]      It remains to be considered whether the Court should exercise an overriding discretion due to the existence of "special circumstances". ...

., the giving must be regarded as not having been perfected and the sailboat must be considered to have continued at all material times to be part of the patrimony of the judgment debtor, and therefore subject to seizure on December 7, 1996, for a tax debt certified in an amount of over $14,000. ...

Finally, it is clear that the terms of the transitional provision, whether the English or the French version is considered, do not have the restrictive character the appellant is seeking to give them. ...

It does not deprive the assessed person of life, liberty or security of the person within the meaning of section 7 of the Charter, and it does not place the assessed person under state control in a manner that could possibly be considered treatment or punishment within the meaning of section 12 of the Charter ...

Since jurisdiction is not engaged, the constitutional arguments cannot be considered. ...

The respondent’s recollection of the same conversation is said to be somewhat inconsistent but could reasonably be considered only to be more detailed (see VDP Second Review Report, appeal book at pages 150 and f ...

In particular, we note that some of the evidence that the Tax Court considered to be inconsistent and unreliable related to the matters with which these certificates and documents were concerned. ...

Thus, the questions to be considered upon the hearing of the application will be (1) whether HOAC’s objection raises a serious issue, (2) whether HOAC will suffer irreparable harm if the stay is not granted, and (3) whether the balance of convenience favours granting or denying the stay (International Charity Association Network v. ...

Krauss in the Tax Court and in this Court that, despite the nominal contributions of the holders of the Class C units, their income allocation was reasonable because it gives effect to the partnership structure chosen for the Partnership, which was functionally analogous to the kind of corporate estate freeze that is generally considered acceptable income tax planning. ...

Nonetheless, even if he erred as the appellants allege, any error was not sufficiently material, when considered in the context of his reasons as a whole, to warrant our intervention ...