TCCA (General Procedure) s. 12(1)
Cases
The Queen v. Carew, 92 DTC 6608 (FCA)
The Crown served its reply to the taxpayer's notice of appeal on the 60th day required by Rule 44(1) but, due to an unexplained failure of the...
TCCA (General Procedure) s. 63(2)
See Also
Foundation Instruments Inc. v. The Queen, 92 DTC 1879 (TCC)
Garron J. found that the appropriate sanction for the Crown filing its Reply three days late (due to an error in calculating the 60-day deadline)...
Discovery Research Systems Inc. v. The Queen, 92 DTC 1306 (TCC)
[C.R: Rule 12(1)]
In denying an extension of the time for filing Replies of the Minister, Bonner J. stated (p. 1307):
"If extensions of the time...
Carew v. The Queen, 92 DTC 1291 (TCC)
In refusing to grant an extension under s. 63(1) in respect of a one-day delay in filing a Reply due to administrative inefficiencies, Kempo J....
Section 16
Cases
C.D. v. Minister of National Revenue, 91 DTC 5210, [1991] 1 CTC 379 (FCA)
After referring (at p. 5211) to the principle "that the courts must administer justice in public", and noting that this principle is subject only...
Section 17.2
See Also
Fio Corporation v. The Queen, 2014 TCC 58
On the same day, the taxpayer delivered its notice of appeal to the Tax Court, informed CRA of the appeal, and delivered its documents and list of...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) | implied undertaking of confidentiality during discovery | 196 |
| Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) | inherent jurisdiction to void reassessments which breach undertaking | 149 |
| Tax Topics - Income Tax Act - Section 241 | s. 241 does not override implied undertaking rule | 153 |
Subsection 18(1)
Articles
Christie A.C.J., "Practice in the Tax Court of Canada", 1991 British Columbia Tax Conference, Volume 1
Subsection 18.15(4)
Cases
Muszka v. The Queen, 94 DTC 6076 (FCA)
A chartered accountant, who was the friend of the taxpayer and allegedly had intimate knowledge of the assessments in question and the business...
Section 18.24
Cases
Ray v. Canada, 2004 DTC 6028, 2004 FCA 1
In rejecting a submission that deference should be given to the interpretation given by the Tax Court below in interpreting s. 118.2(2)(n) of the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(n) | 128 | |
| Tax Topics - Statutory Interpretation - Redundancy/reading in words | 48 |
Gastrebski v. The Queen, 94 DTC 6355 (FCA)
In finding that the standard for review by the Court of Appeal was the same for appeals from informal Tax Court decisions as for appeals from the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Application Rules - Subsection 19(1) | 96 | |
| Tax Topics - Statutory Interpretation - Interpretation Act - Section 12 | 40 |