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The disbursements are justified and considered necessary and reasonable costs for the conduct of this case. ...

., [1994] 1 C.T.C. 2562, in which (then) Associate Chief Judge Christie disallowed fees claimed, and addressed the issue of who could be considered “counsel” before the Court as defined in the Act and Rules. ...

The Court, having considered the provisions of Rule 147 of the Tax Court of Canada Rules (General Procedure) is satisfied that a proper disposition of these matters is to order one set of costs, in the appeals of John Frank Krmpotic (2006‑2354(IT)G) and 507582 B.C.  ...

Terek will not be barred from having this issue properly considered in respect to his father’s assessment and in respect to his own assessments for later years. ...

I find that this trip is more akin to a personal leisure activity and is too remote from the appellant's business to be considered a business expense. ...

In the taxation years 2000 and 2001, (the only years where there could have been an appeal based upon documentation filed that could have been considered to be a notice of objection) the Appellant did not follow the proper procedure. ...

Counsel for the Respondent has, by the written submissions dated October 7, 2004, agreed with the consent of the Appellant and his wife, that although the Appellant, Yash Marwaha was living in the same residence with his wife, Sushma Marwaha, they were nevertheless to be considered as living separate and apart and pursuant to a written agreement, with the result that the said amount of $8,400.00 in each of said three years is to be included in the income of Yash Marwaha and deducted from the income of Sushma Marwaha as contemplated in Sections 56 and 60 of the Income Tax Act. 3.        ...

Lester, in a letter dated January 24, 2003, that he had been allowed a $3,655 deduction for support payments but that he was denied the additional deduction of $14,000 on the ground that a lump sum payment is not considered a support payment under the Act. [5]      On January 31, 2003, the Minister issued a reassessment with regard to Mr. ...

The Minister takes the position that he was separated and in so doing, it reduces the credit for GST and heating expense relief for the Appellant by $279. [5]      The question before me for the taxation years 1999 and 2000 is should the Appellant to be considered separated or did he have a cohabiting spouse? ...

A copy of that agreement was provided to the Court and marked as Exhibit A-3. [5]      In order for the payments made by the Appellant to be deductible under paragraph 60(b) of the Act, they would have to comply with subsection 60.1(3) of the Act. [6]      That provision requires an explicit recognition that the parties to the agreement intended it to apply to prior payments, and must refer to the past payments as having been paid and received under the written agreement. [7]      In this case, the agreement states that the Appellant shall continue to make support payments and that the effective date of the agreement was March 16, 1996. [8]      However, there is no explicit reference to prior payments, to the tax treatments of those payments or that the payments be considered to have been paid and received under the written agreement. [9]      Subsection 60.1(3) is explicit with respect to these requirements. ...