Wall v. Canada,

JurisdictionFederal Jurisdiction (Canada)
Neutral Citation2021 FCA 132
Citation2021 FCA 132
CourtCourt of Appeal (Canada)
Date02 July 2021
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3 practice notes
  • Mann v. The King, 2023 TCC 151
    • Canada
    • Tax Court (Canada)
    • October 24, 2023
    ...378, paras. 4, 23 [26] See calculation in Respondent’s written submissions, para. 33 [27] Wall v. R., 2019 TCC 168, aff’d 2021 FCA 132 for other reasons [28] Thomson v. M.N.R., [1946] SCR 209 [29] Rebus v. R., [2002] 3 CTC 2328 (TCC), para. 23 [30] Act, paragraph 152(3.1)(b) [......
  • River Cree Resort Limited Partnership v. Canada, 2023 FCA 130
    • Canada
    • Court of Appeal (Canada)
    • June 8, 2023
    ...it is not the role of this Court to reweigh the evidence and arrive at a different conclusion than the Tax Court Judge (Wall v. Canada, 2021 FCA 132, at paragraph 28; Barnwell v. Canada, 2016 FCA 150, at para. [44] River Cree has also not established that the Tax Court Judge made a palpable......
  • Simonetta v. The King, 2023 TCC 54
    • Canada
    • Tax Court (Canada)
    • August 11, 2023
    ...(in ¶15) used the term intention. Accordingly, I have used both motive and intention in the above list. [45] Wall v. The Queen, 2021 FCA 132, ¶24. [46] Ibid, ¶25. [47] Exhibit A-1, tab 2, seventh page. [48] As noted above, the third and fourth MLS listings stated that the low......
3 cases
  • Mann v. The King, 2023 TCC 151
    • Canada
    • Tax Court (Canada)
    • October 24, 2023
    ...378, paras. 4, 23 [26] See calculation in Respondent’s written submissions, para. 33 [27] Wall v. R., 2019 TCC 168, aff’d 2021 FCA 132 for other reasons [28] Thomson v. M.N.R., [1946] SCR 209 [29] Rebus v. R., [2002] 3 CTC 2328 (TCC), para. 23 [30] Act, paragraph 152(3.1)(b) [......
  • River Cree Resort Limited Partnership v. Canada, 2023 FCA 130
    • Canada
    • Court of Appeal (Canada)
    • June 8, 2023
    ...it is not the role of this Court to reweigh the evidence and arrive at a different conclusion than the Tax Court Judge (Wall v. Canada, 2021 FCA 132, at paragraph 28; Barnwell v. Canada, 2016 FCA 150, at para. [44] River Cree has also not established that the Tax Court Judge made a palpable......
  • Simonetta v. The King, 2023 TCC 54
    • Canada
    • Tax Court (Canada)
    • August 11, 2023
    ...(in ¶15) used the term intention. Accordingly, I have used both motive and intention in the above list. [45] Wall v. The Queen, 2021 FCA 132, ¶24. [46] Ibid, ¶25. [47] Exhibit A-1, tab 2, seventh page. [48] As noted above, the third and fourth MLS listings stated that the low......

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