Cases
Canada v. Csak, 2025 FCA 60
Two months after their marriage, the taxpayer received from her husband (“CC”) the transfer of a property valued in excess of his subsequently...
Tedesco v. Canada, 2019 FCA 235
The appellants were partners of a limited partnership (“TSI”). On March 29, 2006, the Minister issued Notices of Determination pursuant to s....
Canada v. ACI Properties Ltd., 2014 DTC 5036 [at at 6718], 2014 FCA 45
Another taxpayer ("AFT") made a payment to the appellant ("ACI") of $1.95 million, which it characterized as a deductible management fee and ACI...
Canada (National Revenue) v. RBC Life Insurance Company, 2013 FCA 50
The taxpayers offered "10-8" insurance plans to their customers, which generated exempt income and deductible interest. Under a 10-8 plan, the...
Special Risks Holdings Inc. v. The Queen, 84 DTC 6054, [1984] CTC 71 (FCTD), aff'd 84 DTC 6215, [1984] CTC 563 (FCA)
"It is inherent in the good faith application of the Rule that further discoveries of documents will not be sought or further investigations made...
Medicine Hat Greenhouse Ltd. and German v. R., [1980] CTC 114 (Alta. C.A.)
Assuming the absence of fraudulent intent or improper motive involved in specifying the date contained in the certificate, the certificate is...
See Also
Stewart v. The Queen, 2018 TCC 75, rev'd on TCCA s. 16.2/no abuse of process grounds 2019 FCA 235
The appellants were partners of a limited partnership (“TSI”). On March 29, 2006, the Minister issued Notices of Determination pursuant to s....
Construction S.Y.L. Tremblay Inc. v. Agence du revenu du Québec, 2018 QCCA 552
In the federal Construction S.Y.L. Tremblay case, Bédard J found that house-repair invoices, that did not give the house address or describe the...
McIntyre v. The Queen, 2014 DTC 1116 [at at 3258], 2014 TCC 111
Two of the taxpayers were convicted based on a plea-bargain. The Minister's subsequent assessments of the taxpayers was based on amounts greater...
Congiu v. The Queen, 2013 TCC 271, aff'd 2014 FCA 73
The appellant was appealing an assessment made by Revenue Quebec on behalf of the (federal) Minister under s. 270(4) of the Excise Tax Act in...
Houda International Inc v. The Queen, 2010 TCC 622, [2011] GSTC 8
The taxpayer was granted an extension from the Court of Quebec in its QST appeal on the basis that it was not at fault for its lawyer’s failure...
Golden v. The Queen, 2008 DTC 3363, 2008 TCC 173
Issue estoppel applied to preclude the taxpayer from litigating before the Tax Court the question whether an amount of $34,000 should have been...