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TCC

Oddleifson v. The Queen, 2021 TCC 26

Oddleifson describes at length how that third option made her feel, how she considered it when deciding what to do and why it was unappealing to her. [15] On the basis of the foregoing, I conclude that Ms. ...
FCTD

Célestin v. Canada (Public Safety and Emergency Preparedness), 2021 FC 223

Having considered the submissions of the parties, the Court fixes costs at $2,000.   ...
FCTD

Hervé Pomerleau Inc. v. R., [1996] 2 CTC 251

Accordingly, this notice must be considered nonexistent and the “fiscal change” referred to in clause 22.4 of the general Conditions is not deemed to have occurred prior to the date at which the bids were presented. ...
TCC

Rand v. R., [1996] 2 CTC 2410, 97 DTC 435

Her actions in personally reviewing the prospective tenants for 2460 in September 1988 indicate to the Court that she still considered 2458 as her home in September. ...
TCC

Fraser v. R., [1996] 2 CTC 2631 (Informal Procedure)

I however pointed out to Counsel subsections 160.1(1) and 160.1(3) of the Act which read as follows: 160.1(1) Where at any time the Minister determines that an amount has been refunded to a taxpayer for a taxation year in excess of the amount to which he was entitled as a refund under this Act, the following rules apply: (a) the excess shall be deemed to be an amount that became payable by the taxpayer on the day on which the amount was refunded; and (b) the taxpayer shall pay to the Receiver General interest at the prescribed rate on the excess (other than any portion thereof that may reasonably be considered to arise as a consequence of the operation of section 122.5) from the day it became payable to the date of payment. 160.1(3) The Minister may at any time assess a taxpayer in respect of any amount payable by the taxpayer because of subsection (1) or (1.1) or for which the taxpayer is liable because of subsection (2) or (2.1), and the provisions of this Division apply, with such modifications as the circumstances require, in respect of an assessment made under this section as though it had been made under section 152. ...
FCA

Perrier Group of Canada Inc. v. Canada, [1996] 1 CTC 167

The Tribunal considered the nature of Perrier water, however, and concluded that it was a prepared product. ...
TCC

Vaccarello v. R., [1996] 1 CTC 2408, 96 DTC 1934

I cannot conclude from the evidence that the appellants considered in 1988 that they simply borrowed $38,000 from Tripemco. ...
TCC

Saikali v. R., [1996] 1 CTC 2547, 98 DTC 2249

The meaning of the term “gross negligence” used in section 163 of the Act was considered in Venne v. ...
TCC

McDonald v. R., [1996] 1 CTC 2585, 98 DTC 2223

My view is that it is the Audias, who made the payment with funds borrowed from the appellant or advanced by him, who should be considered guarantors for the purpose of that provision. ...
TCC

Faucher v. R., [1996] 1 CTC 2734, 96 DTC 3211 (Informal Procedure)

The appellants contended that the purchaser and the vendor were dealing with each other at arm’s length and that the price of $3,454,414 actually paid must be considered as the true value, particularly since the respondent admitted that the building’s fair market value in March 1987, that is a month and a half prior to the sale, was $3,450,000, that is only $4,414.00 less than the price actually paid. ...

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