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This was reasonable notwithstanding the Board’s description of section 32 as providing a presumption that provincial limitation periods apply, a statement about which I have considerable doubt. [16] Finally, the applicant submits, the Board failed to reasonably justify its departure from its own decision in Dansou and from Markevich when it concluded the cause of action arose “otherwise than in a province”: Applicant’s Memorandum of Fact and Law at para. 25. [17] Over several paragraphs in its reasons, the Board discussed both cases and explained why it considered them distinguishable and not determinative of the question before it: see reasons at paras. 76-89. ...

It is understandable why the objections and correspondence submitted by the appellant in 2019 were considered by the Minister under administrative relief, because there were no remaining avenues by then. [26] Unfortunately, neither the Court nor the Minister has the power to extend the time to object where a person does not make their request within the one year permitted by the Act. [32] Based on the timeline of events, the appellant took his various steps after the time limits had passed and as a result, there is no power or discretion left for the Minister or the Court to exercise under the law. ...

The Court (at para 13) considered whether a similar rule in the Federal Court Rules could be used to extend a limitation period in the Customs Act and held that it could not: Furthermore, it seems clear to me on a plain reading of Rules 6 and 302 that they have no application to the case at hand. ...

While I acknowledge that the resulting subsection 163(1) penalty is harsh, that is a matter for Parliament to address. [24]         In reaching this conclusion, I have considered the cases provided by counsel in the Joint Book of Authorities, including the decision of the Tax Court of Canada in Galachiuk v. ...

So, each amount of support payable under an agreement or order that is not specifically identified as being solely for spousal support, is considered to be child support. [27] Element C is the total amounts each of which is a support amount paid by the taxpayer to the particular person after 1996 and is deductible in computing the taxpayer’s income for a preceding taxation year. ...

The same document, as well as the CRA officer’s Second Review Report, list all the art sold (and at what price) in their summaries of evidence, indicating that the officer had indeed considered the amount claimed: CRA officer’s notes, CTR at 27. ...

Benny considered the additional expenses claimed as clearly not reasonable in the circumstances ...

The Queen, [2] Woods J. considered documentary evidence over viva voce evidence in deciding the character of a settled amount. ...

Zaugg could specifically update his mailing address for the purposes of the determination of his eligibility for the disability tax credit. [27] The facts of this case are distinguishable from those considered by Justice Wong in Pour Afkari v The Queen, 2019 TCC 173. ...

All of the documents attached to the Applicant’s various March 21, 2024 and March 24, 2024 emails, along with those emails themselves, are deemed to comprise part of the record that will be considered in that proceeding. [23] The parties proposed no question for certification, and I agree that none arises. ...