Choptiany v. The King, 2022 TCC 112
| Jurisdiction | Federal Jurisdiction (Canada) |
| Court | Tax Court (Canada) |
| Citation | 2022 TCC 112 |
| Date | 05 October 2022 |
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6 practice notes
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Choptiany Et. Al. v The King, 2022 TCC 112: The Tax Court Of Canada Issues Scathing Rebuke Of CRA's "Outrageously Misleading And Inappropriate" Litigation Tactics In Tax Dispute Involving Gross-Negligence Penalties
...as a matter of course when concluding a tax audit. We see yet another egregious example of this practice in Choptiany et. al. v The King, 2022 TCC 112. But what's more, in Choptiany, the CRA not only applied gross-negligence penalties with seemingly insufficient justification, but also empl......
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Azzopardi v. The King, 2023 TCC 51
...Leroux v Canada Revenue Agency, 2014 BCSC 720, Agence du revenue du Quebec c Groupe Enico, 2016 QCCA 76, and Choptiany v The King, 2022 TCC 112. Finally, at paragraph 5 of his Notice of Appeal under “Issues to be Raised” he pleaded an issue with respect to the existence, sendi......
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Taxpayers' Appeals Allowed Due To Cra's Repeated Non-Compliance
...non-compliance, go a long way towards enhancing the public's respect for the judicial process. Footnotes 1. Choptiany v. H.M.K., 2022 TCC 112. Read the original article on The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be s......
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The Tax Court Of Canada Orders The Canada Revenue Agency To Release GAAR Committee Reports About Similarly Situated Taxpayers: Coopers Park Real Estate Development V The Queen, 2022 TCC 82
...example, the decision doesn't compel the CRA to release privileged documents.) But as we've recently seen in Choptiany et. al. v The King, 2022 TCC 112, the CRA's tax counsel at the Department of Justice may employ pre-trial tactics aimed at misleading the other side and undermining the dis......
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2 cases
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Azzopardi v. The King, 2023 TCC 51
...Leroux v Canada Revenue Agency, 2014 BCSC 720, Agence du revenue du Quebec c Groupe Enico, 2016 QCCA 76, and Choptiany v The King, 2022 TCC 112. Finally, at paragraph 5 of his Notice of Appeal under “Issues to be Raised” he pleaded an issue with respect to the existence, sendi......
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Estate of Terry Urbanowski et al. v. The King, 2024 TCC 6
...L.L.P. Winnipeg, Manitoba For the Respondent: Shalene Curtis-Micallef Deputy Attorney General of Canada Ottawa, Canada [1] 2022 TCC 112. [2] 2019 FCA 210. [3] 2017 TCC 123. This was an appeal that I heard before I was appointed case management judge of the Fiscal Arbitrator [4] 2022 ......
4 firm's commentaries
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Choptiany Et. Al. v The King, 2022 TCC 112: The Tax Court Of Canada Issues Scathing Rebuke Of CRA's "Outrageously Misleading And Inappropriate" Litigation Tactics In Tax Dispute Involving Gross-Negligence Penalties
...as a matter of course when concluding a tax audit. We see yet another egregious example of this practice in Choptiany et. al. v The King, 2022 TCC 112. But what's more, in Choptiany, the CRA not only applied gross-negligence penalties with seemingly insufficient justification, but also empl......
-
Taxpayers' Appeals Allowed Due To Cra's Repeated Non-Compliance
...non-compliance, go a long way towards enhancing the public's respect for the judicial process. Footnotes 1. Choptiany v. H.M.K., 2022 TCC 112. Read the original article on The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be s......
-
The Tax Court Of Canada Orders The Canada Revenue Agency To Release GAAR Committee Reports About Similarly Situated Taxpayers: Coopers Park Real Estate Development V The Queen, 2022 TCC 82
...example, the decision doesn't compel the CRA to release privileged documents.) But as we've recently seen in Choptiany et. al. v The King, 2022 TCC 112, the CRA's tax counsel at the Department of Justice may employ pre-trial tactics aimed at misleading the other side and undermining the dis......
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Tax Court Of Canada Rules That Vendor Avoids Derivative Tax Liability When Selling Property To Tax-Motivated Arm's-Length Buyer; The Transaction Also Failed To Trigger The General Anti-Avoidance Rule
...rule under section 245 of Canada's Income Tax Act. Moreover, as we've recently seen in cases like Choptiany et. al. v The King, 2022 TCC 112, the CRA's tax counsel at the Department of Justice may employ pre-trial tactics aimed at misleading the other side and undermining the discovery proc......