Canada v. JES Investments Ltd., 2007 FCA 337 (2007)

Extract

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Canada v. JES Investments Ltd., 2007 FCA 337 (2007)

Date: 20071026

Docket: A-474-06

Citation: 2007 FCA 337

CORAM: LINDEN J.A.

NOËL J.A.

RYER J.A.

BETWEEN:

HER MAJESTY THE QUEEN

Appellant

and

JES INVESTMENTS LTD.

Respondent

Heard at Regina, Saskatchewan , on October 9, 2007.

Judgment delivered at Ottawa, Ontario , on October 26, 2007.

REASONS FOR JUDGMENT BY: RYER J.A.

CONCURRED IN BY: LINDEN J.A.

NOËL J.A.

Date: 20071026

Docket: A-474-06

Citation: 2007 FCA 337

CORAM: LINDEN J.A.

NOËL J.A.

RYER J.A.

BETWEEN:

HER MAJESTY THE QUEEN

Appellant

and

JES INVESTMENTS LTD.

Respondent

REASONS FOR JUDGMENT

RYER J.A.

[1] This is an appeal from a decision of Sheridan J. (2006 TCC 508) of the Tax Court of Canada, dated September 27, 2006, allowing an appeal of JES Investments Ltd. (the “taxpayer”) against a reassessment that was issued in respect of its 1998 taxation year by the Minister of National Revenue (the “Minister”), pursuant to the Income Tax Act , R.S.C. 1985, c. 1 (5th Supp.) (the “ITA”), and that ...

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