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TCC

Desmarais v. The Queen, 2013 DTC 1044 [at at 2804], 2013 TCC 356 (Informal Procedure)

I do not believe the appellant's interpretation of the facts can be considered unreasonable in the circumstances ...
FCA

Canada v. Anchor Pointe Energy Ltd., 2003 DTC 5512, 2003 FCA 294

He considered it to be a conclusion of law "that has no place among the Minister's assumed facts". [25]            I agree that legal statements or conclusions have no place in the recitation of the Minister's factual assumptions. ...
FCA

Holbrook v. Canada, 2007 DTC 5336, 2007 FCA 145

He reached that conclusion because he considered himself bound to follow the decision of this Court in Kennedy v. ...
TCC

Card v. The Queen, 2000 DTC 1976 (TCC)

As far as Exhibit A-2 – and this is my last question – would you agree that if the partnership had considered it fair to adjust the incomes of all partners on the basis of the WIP being shared in accordance with the partnership, that the resulting schedule would be the one that appears as alternative A? ...
FCA

Shabro Investments Ltd. v. The Queen, 79 DTC 5104, [1979] CTC 125 (FCA)

Thus, while undoubtedly the function to be performed by the subject matter of a renewal, repair or replacement is an element to be considered in characterizing the nature of the work, it is only one element and must be examined, as I see it, against the whole background of the work. ...
FCA

Robinson (Trustee Of) v. R., 98 DTC 6065, [1998] 1 CTC 272 (FCA)

The Tax Court Judge also considered some of the language in sections 52 and 53, subsection 54(1), section 62 and subsection 63(1) of that statute. [1] After doing so, he concluded as follows, at p. 4: Thus a common law partnership is the relationship between persons carrying on a business in common with a view to profit. ...
TCC

Gill v. The Queen, 2012 DTC 1261 [at at 3764], 2012 TCC 302

Borins J. considered the language of subsection 62(1) of the Law Society Act, which stated:   Subject to section 63, Convocation may make rules relating to the affairs of the Society and, without limiting the generality of the foregoing,. . .   6. providing for the time and manner of and the methods and procedures for the election of benchers ...
FCTD

Blanchard v. The Queen, 92 DTC 6585, [1992] 2 CTC 403 (FCTD)

The purpose behind paragraph 6(1)(a) of the Act was considered by this Court in McNeil] v. ...
FCTD

Weinkauf v. The Queen, 85 DTC 5570, [1985] 2 CTC 354 (FCTD), briefly aff'd [1988] 1 CTC 231 (FCA)

The period of his unemployment cannot have been fully 14 months, as alleged, but, for lack of a precise date, ought to be considered as 13 months at most. ...
FCA

The Queen v. Bank of Nova Scotia, 81 DTC 5115, [1981] CTC 162 (FCA)

When section 126(1)(a) is considered by itself or in isolation and without taking into account normal accounting practices or any other factors, it would seem to be more natural and normal to calculate the value of the tax in Canadian dollars at the rate of exchange in effect at the date of payment, although there is nothing in the sections which actually requires this. ...

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