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FEDERAL INCOME TAX - Appeals - Tax Court of Canada - Motions - Evidence on motions

Monday, May 01, 2017 @ 7:18 AM  

Appeal by CBS Canada from a Tax Court decision striking an affidavit. CBS appealed the Minister's reassessment in respect of the application of certain non-capital losses to income in particular taxation years. Counsel for CBS proposed a settlement offer which included a schedule of CBS's losses. The parties finalized minutes of settlement that incorporated the schedule. Thereafter, the Minister concluded that no non-capital losses were available to CBS. CBS filed a motion to enforce the settlement. The deponent of the supporting affidavit was a lawyer within...