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Dropsy are considered necessary to assist in completing the audit as well as verifying the admissibility of the members’ investments.   ...

Her Majesty the Queen       MOTION IN WRITING CONSIDERED AT OTTAWA, ONTARIO PURSUANT TO RULE 369   REASONS FOR ORDER AND ORDER:                                    Harrington J.   ...

Nixon’s case I considered substituting a ss. 163(2) penalty as had such a penalty been assessed, the penalty amount would have been reduced to $23,244, which is a savings of $13,522, calculated as:   Federal tax payable- $28, 826.09 X 50%        $14,413.05 Provincial tax payable- $17, 663.52 X 50%     $8,831.76 ss. 163(2) penalties                                           $23, 244.78 Less: ss. 163(1) penalties already assessed        $ 36,797.60 Decrease in penalties                                        $13, 552.82   Subsection 163(2) penalties apply to increases in income of more than $5,000 and as such, the $183,988 increase to Mr. ...

. … The circumstances presented in your submission are not considered extraordinary. ...

The generally accepted definition of “receivable” is that for an amount to be considered receivable, “it is not enough that the so-called recipient have a precarious right to receive the amount in question, […] he must have a clearly legal, though not necessarily immediate, right to receive it” (Minister of National Revenue v Colford Contracting Company Limited, 60 DTC 1131). [19]            Amendment #6 sets out the clear and unconditional right of Alberta to receive its share of Deemed Net Profit. ...

Rhéaume and stated that she had considered the entire file as well as the presentation made by Ms. ...

(i)       On August 15, 2011, the CRA wrote to the Applicant to inform him that his request for an adjustment to his 2000 return under the taxpayer relief provisions could not be considered because it was received after the ten-year limitation period.                              ...

As for the guarantor identified by the applicant, it was not considered entirely credible that someone who claims to be a friend would agree to incur such costs over the next five years. ...

The RAD’s April 4, 2016 decision [9]                The matter before our Court is the RAD’s decision dismissing the applicant’s appeal, confirming the RPD’s decision and finding that he did not have status as a Convention refugee or a person in need of protection under Sections 96 and 97 of the IRPA. [10]            The RAD admitted new evidence that the applicant presumably resided in Zogota at the time of the events at the heart of his claim for refugee protection, but it considered this fact to be secondary in assessing his credibility and did not change the outcome of his claim. ...

The RAD considered only a portion of an official report by the Immigration and Refugee Board of Canada and did not consider the documentary evidence contradicting its conclusion that the applicant would be protected in Senegal. ...