Date: 20130919
Docket: A-553-12
Citation: 2013 FCA 221
CORAM: SHARLOW J.A.
STRATAS J.A.
NEAR J.A.
BETWEEN: |
NRT TECHNOLOGY CORP. |
Appellant |
and |
HER MAJESTY THE QUEEN |
Respondent |
Heard at Toronto, Ontario, on September 19, 2013.
Judgment delivered from the Bench at Toronto, Ontario, on September 19, 2013.
REASONS FOR JUDGMENT OF THE COURT BY: SHARLOW J.A.
Date: 20130919
Docket: A-553-12
Citation: 2013 FCA 221
CORAM: SHARLOW J.A.
STRATAS J.A.
NEAR J.A.
BETWEEN: |
NRT TECHNOLOGY CORP. |
Appellant |
and |
HER MAJESTY THE QUEEN |
Respondent |
REASONS FOR JUDGMENT OF THE COURT
(Delivered from the Bench at Toronto, Ontario, on September 19, 2013)
SHARLOW J.A.
[1] This is an appeal of a judgment of Justice Campbell Miller of the Tax Court of Canada dismissing an appeal of a reassessment under the Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.) for the 2007 taxation year (2012 TCC 420). The issue is whether the appellant, NRT Technology Corp.,
Page: 3
is entitled to a deduction for certain pre-2007 non-capital losses of a corporation it acquired in 2006 with which it was subsequently amalgamated.
[2] Despite the able submissions of counsel for NRT, we have been unable to discern any error of law or fact on the part of Justice Miller.
[3] The appeal will be dismissed with costs.
“K. Sharlow”
J.A.
FEDERAL COURT OF APPEAL
NAMES OF COUNSEL AND SOLICITORS OF RECORD
DOCKET: A-553-12
APPEAL FROM AN ORDER OF THE HONOURABLE JUSTICE CAMPBELL J. MILLER OF THE TAX COURT OF CANADA DATED NOVEMBER 30, 2012, IN COURT FILE NO. 2010-1901 IT(G).
DOCKET: |
A-553-12
|
STYLE OF CAUSE: |
NRT TECHNOLOGY CORP. v. HER MAJESTY THE QUEEN
|
PLACE OF HEARING: TORONTO, ONTARIO
DATE OF HEARING: SEPTEMBER 19, 2013
REASONS FOR JUDGMENT OF THE COURT BY: SHARLOW J.A.
STRATAS J.A.
NEAR J.A.
DELIVERED FROM THE BENCH BY: SHARLOW J.A.
APPEARANCES:
David Chodikoff Tarsem Basraon
|
FOR THE APPELLANT
|
Rita Araujo Arnold Bornstein
|
FOR THE RESPONDENT
|
SOLICITORS OF RECORD:
Miller Thompson LLP Toronto, Ontario
|
FOR THE APPELLANT
|
William F. Pentney Deputy Attorney General of Canada
|
FOR THE RESPONDENT
|