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TCC

Jarrold v. The Queen, 2009 TCC 164 (Informal Procedure)

In this particular case, the Court is satisfied that it can distinguish the facts here from the facts that Justice Bowman considered in his case. ...
TCC

Ince-Mercer v. M.N.R., 2009 TCC 594

In order to resolve this question, which has been variously characterized in the jurisprudence as ‘fundamental’, ‘central’ and ‘key’, the total relationship of the parties and the combined force of the whole scheme of operations must be considered. ...
TCC

Szlavy v. The Queen, 2009 TCC 449

Some of the evidence submitted to the Tax Court was in fact considered a sham to hide the truth of what was actually happening ...
TCC

Payette v. The Queen, 2009 TCC 348

In preparing these reasons I have considered whether or not a business was carried on, irrespective of whether it was carried on by Mr.  ...
TCC

Coates v. The Queen, 2009 TCC 366 (Informal Procedure)

As there is no issue in respect of 2004, only the 2003 record need be considered. ...
TCC

Herroug c. La Reine, 2007 TCC 672

In that respect, he produced a letter from the Ministère du Revenu du Québec dated August 30, 2004 (Exhibit A-1), which confirms that the Appellant was considered an employee for the services rendered from January 1, 1999, to December 31, 2001, to GR and that, as a result, GR had to pay his Québec Pension Plan contributions. ...
TCC

Highway Customs Warehouse Ltd v. The Queen, 2007 TCC 715

Considering that the Court in Yost offered no rationale for its decision to amend the earlier judgment, and made no mention of Gunnar Mining, Paper Machinery or any of the English authorities cited in those cases, and considering, too, that it is not referred to in the more recent decisions of the Federal Court of Appeal, I conclude that Yost should be considered to have been decided per incuriam ...
TCC

Rose v. The Queen, 2007 TCC 657

Hoping to fend off what he considered Holyoak's "bogus claim", Hally somehow came up with the idea of getting his name off the title of the family home. ...
TCC

Katzenback v. The Queen, 2007 TCC 693, 2007 TCC 683 (Informal Procedure)

He considered a variety of import products, primarily from India but from other countries as well. ...
TCC

9030-2340 Québec Inc. c. La Reine, 2007 TCC 759

The resulting figure was considered to represent 8.25% of sales.   [17]     The appellant does not dispute the amount of the purchases. ...

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