Estoppel

Table of Contents

Commentary

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Cases

Tuccaro v. Canada, 2014 DTC 5103 [at 7210], 2014 FCA 184

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Stare Decisis prior finding about the meaning of an aboriginal treaty was a finding of fact, not of law 148
Tax Topics - Other Legislation/Constitution - Federal - Indian Act - Section 87 prior decision on treaty was finding of fact, not law 148

Ludmer v. The Queen, 95 DTC 5311 (FCA)

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Duthie Estate v. The Queen, 95 DTC 5376 (FCTD)

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The Queen v. Jasper, 94 DTC 6519 (FCTD)

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Optical Recording Corp. v. The Queen, 86 DTC 6465, [1986] 2 CTC 454 (FCTD), aff'd 87 DTC 5248, [1987] 1 CTC 417

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) notice of assessment that did not assess tax that was yet due was a nullity 181
Tax Topics - Income Tax Act - Section 195 - Subsection 195(2) 29

The Queen v. Metropolitan Properties Co. Ltd., 85 DTC 5128, [1985] 1 CTC 169 (FCTD)

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384238 Ontario Limited v. The Queen, 84 DTC 6101, [1984] CTC 523 (FCA)

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Cornforth v. The Queen, 82 DTC 6058, [1982] CTC 45 (FCTD)

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Wilchar Construction Ltd. v. The Queen, 81 DTC 5318, [1981] CTC 415 (FCA)

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Brown v. The Queen, 79 DTC 5421, [1979] CTC 476 (FCTD)

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The Queen v. Moulds, 78 DTC 6068, [1978] CTC 146 (FCA)

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Tax Topics - Income Tax Act - Section 68 98

Hnatiuk v. The Queen, 76 DTC 6376, [1976] CTC 632 (FCTD)

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See Also

International Hi Tech Industries Inc. v. The Queen, 2018 TCC 107 (Informal Procedure)

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Tax Topics - Excise Tax Act - Section 225 - Subsection 225(4) - Paragraph 225(4)(b) timely but invalid claiming of ITCs by parent did not now permit sub to claim them after 4 years 203

St-Pierre v. The Queen, 2017 CCI 69, rev'd 2018 CAF 144

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(2) judicial nullification rather rectification of a premature capital dividend declaration gave rise to a s. 15(2) income inclusion 479
Tax Topics - General Concepts - Unjust Enrichment taxpayer was unjustly enriched when he received capital dividends that subsequently were declared to not have been validly paid as dividends 81

Dundurn Street Lofts Inc. v. The Queen, 2010 TCC 553

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Harvest Operations Corp v. A.G. (Canada), 2015 DTC 5067 [at 5904], 2015 ABQB 327

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Tax Topics - General Concepts - Rectification & Rescission requested rectification order to fix bump did not match parties' specific plan at closing 542
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(c) failure to fund debt repayment through increased purchase price 152

Szymczyk v. The Queen, 2014 TCC 380 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Onus Minister's "partly arbitrary" assumptions did not remove onus from taxpayer 317
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(k) late designation not permitted/rule-of-thumb method invalidated by s. 6(1)(k) 189
Tax Topics - Income Tax Act - Section 6 - Subsection 6(2) separate personal use kilometers required for each vehicle used in year 169

Yourkin v. The Queen, 2014 DTC 1071 [at 3032], 2014 TCC 48 (Informal Procedure)

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Tax Topics - General Concepts - Res Judicata taxpayer's seventh collateral attack on the same consent judgment 127

Mosher v. The Queen, 2014 DTC 1026 [at 2654], 2013 TCC 378

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Klundert v. The Queen, 2013 DTC 1166 [at 910], 2013 TCC 208, aff'd 2014 DTC 5087 [at 7098], 2014 FCA 155

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Kreuz v. The Queen, 2012 DTC 1201 [at 3514], 2012 TCC 238 (Informal Procedure)

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741290 Ontario Inc. v. The Queen, 2011 DTC 1089 [at 489], 2011 TCC 91, aff'd 2012 DTC 5025 [at 6665], 2011 FCA 361

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Res Judicata 162

742190 Ontario Inc.(Van Del Manor Nursing Homes) v. Canada (Customs and Revenue Agency), 2010 DTC 5104 [at 6945], 2010 FCA 162

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Cranston v. The Queen, 2010 TCC 414, 2010 DTC 1280 at 3948

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Golden v. The Queen, 2008 DTC 3363, 2008 TCC 173

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Abuse of Process relitigating an amount determined in criminal sentencing 173
Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) 42

Beauchamp v. The Queen, 2006 DTC 3173, 2004 TCC 371 (Informal Procedure)

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Humphrey v. The Queen, 2006 DTC 2730, 2006 TCC 168 (Informal Procedure)

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Stremler v. The Queen, 2000 DTC 1757 (TCC)

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Desrochers v. The Queen, 2000 DTC 962 (TCC)

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Goldstein v. The Queen, 96 DTC 1029 (TCC)

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Taylor v. The Queen, 95 DTC 591 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) 59

Byrt v. MNR, 91 DTC 923 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(3) 92

IRC v. Garvin, [1981] 1 WLR 793 (HL)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) presumption against taxation both as capital and income receipt 53

Articles

Timothy Fitzsimmons, "Advanced Warning", CA Magazine, August 2008, p. 30

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