Recent Posts

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  Boroumend v. R. - TCC: Court rejects taxpayer’s evidence that he never received confirmation of assessment

  Nov 22, 2016 By Bill Innes

  Categories:

  • Bill Innes on Current Tax Cases
  • Federal Income Tax
  • Personal Tax, Estate & Wealth Planning

  Précis: The Crown moved to quash the taxpayer’s appeal of his 2003 and 2004 taxation years on the basis that it was out of time. The taxpayer argued that it was not out of time since he had never received a notice of confirmation of the assessment. While the Court found that CRA’s file was sloppy, it drew a negative inference from several aspects of the taxpayer’s conduct and concluded that he had in fact received the notice of confirmation as alleged by CRA meaning that his appeal was commenced more than 5 years after the time permitted under the Act. Costs were awarded to the Crown.
  Boroumend v. R. - TCC: Court rejects taxpayer’s evidence that he never received confirmation of assessmentREAD MORE »
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  Rossi v. R. - TCC: Court dismisses appeal filed four years late

  Aug 27, 2015 By Bill Innes

  Categories:

  • Bill Innes on Current Tax Cases
  • Federal Income Tax
  • Personal Tax, Estate & Wealth Planning

  Précis: Mr. Rossi was reassessed for 2003 in 2006; he filed a notice of objection in a timely manner. In 2010 CRA confirmed the 2003 reassessment by letter sent to Mr. Rossi by registered mail with a copy by first class mail to his accountant. When the letter sent to Mr. Rossi was returned to CRA unclaimed, it sent the letter to Mr. Rossi again, this time by first class mail, also in 2010. Mr. Rossi and his accountant claimed that in reviewing his account with CRA it was not clear that the 2003 reassessment had been confirmed. In 2014 Mr. Rossi filed a notice of appeal in the Tax Court and CRA moved to have it dismissed.
  Rossi v. R. - TCC: Court dismisses appeal filed four years lateREAD MORE »
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  O’Byrne v. R. – TCC: Tax Court cannot relieve against old tax debts applied to current Canada Pension Plan payments

  Jun 07, 2014 By Bill Innes

  Categories:

  • Bill Innes on Current Tax Cases
  • Federal Income Tax
  • Personal Tax, Estate & Wealth Planning

  
  O’Byrne v. R. – TCC: Tax Court cannot relieve against old tax debts applied to current Canada Pension Plan paymentsREAD MORE »
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  Yarmoloy v. R. – TCC: Application to extend time to file Notice of Appeal denied for lack of evidence

  Feb 04, 2014 By Bill Innes

  Categories:

  • Bill Innes on Current Tax Cases
  • Federal Income Tax
  • Personal Tax, Estate & Wealth Planning

  
  Yarmoloy v. R. – TCC: Application to extend time to file Notice of Appeal denied for lack of evidenceREAD MORE »
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  Kamangar v. R. – TCC: Court Refuses to Grant Taxpayer Second Extension of Time to File Notice of Appeal

  Dec 11, 2013 By Bill Innes

  Categories:

  • Bill Innes on Current Tax Cases
  • Federal Income Tax
  • Personal Tax, Estate & Wealth Planning

  
  Kamangar v. R. – TCC: Court Refuses to Grant Taxpayer Second Extension of Time to File Notice of AppealREAD MORE »