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Case information

Conduct a refined search of the Supreme Court of Canada database to obtain details on the status of a matter before the Court.


41423

Mohammad Yadgar v. His Majesty the King

(Federal) (Civil) (By Leave)

Docket

Judgments on applications for leave to appeal are rendered by the Court, but are not necessarily unanimous.

List of proceedings
Date Proceeding Filed By
(if applicable)
2025-08-29 Close file on Leave
2025-08-29 Correspondence (sent by the Court) to, parties, RE: Certificate of Taxation
2025-08-28 Certificate of taxation issued to, Amin Nur
2025-08-28 Decision on the bill of costs, in the amount of $1,002.70, Reg
2025-08-28 Submission of the bill of costs, Reg
2025-05-06 Bill of costs, UNDER REVIEW, Completed on: 2025-05-09 His Majesty the King
2025-02-06 Copy of formal judgment sent to Registrar of the Court of Appeal and all parties
2025-02-06 Judgment on leave sent to the parties
2025-02-06 Judgment of the Court on the application for leave to appeal, The application for leave to appeal from the judgment of the Federal Court of Appeal, Number A-201-23, 2024 FCA 107, dated June 7, 2024, is dismissed with costs.
Dismissed, with costs
2024-12-16 All materials on application for leave submitted to the Judges, for consideration by the Court
2024-10-15 Applicant's reply to respondent's argument, (Book Form), Completed on: 2024-10-16, (Printed version due on 2024-10-22) Mohammad Yadgar
2024-10-04 Certificate (on limitations to public access), (Letter Form), Form 23A, (Printed version due on 2024-10-11) His Majesty the King
2024-10-04 Respondent's response on the application for leave to appeal, (Letter Form), Completed on: 2024-10-07, (Printed version due on 2024-10-11) His Majesty the King
2024-09-09 Letter acknowledging receipt of a complete application for leave to appeal, File opened 2024-09-09
2024-09-06 Notice of name, (Printed version due on 2024-09-13) Mohammad Yadgar
2024-09-06 Certificate (on limitations to public access), Form 23B, (Printed version due on 2024-09-13) Mohammad Yadgar
2024-09-06 Certificate (on limitations to public access), Form 23A, (Printed version due on 2024-09-13) Mohammad Yadgar
2024-09-06 Application for leave to appeal, (Book Form), (3 volumes), Completed on: 2024-09-06, (Printed version due on 2024-09-13) Mohammad Yadgar

Parties

Please note that in the case of closed files, the “Status” column reflects the status of the parties at the time of the proceedings. For more information about the proceedings and about the dates when the file was open, please consult the docket of the case in question.

Main parties

Main parties - Appellants
Name Role Status
Yadgar, Mohammad Applicant Active

v.

Main parties - Respondents
Name Role Status
His Majesty the King Respondent Active

Counsel

Party: Yadgar, Mohammad

Counsel
Osborne G. Barnwell
Osborne G. Barnwell
515 Consumers Road Ste. 202
North York, Ontario
M2J 4W9
Telephone: (416) 773-0309
FAX: (416) 773-0909
Email: obarnwell@ogblaw.com

Party: His Majesty the King

Counsel
Amin Nur
Department of Justice
120 Adelaide Street West,
Suite 400, National Litigation Sector
Toronto, Ontario
M5H 1T1
Telephone: (437) 324-4422
FAX: (416) 973-0810
Email: amin.nur@justice.gc.ca
Agent
Christopher Rupar
Department of Justice
Civil Litigation Branch, East Tower
234 Wellington Street
Ottawa, Ontario
K1A 0H8
Telephone: (613) 941-2351
FAX: (613) 954-1920
Email: crupar@justice.gc.ca

Summary

Keywords

Taxation — Income tax — Assessment and reassessment — Penalties — In reassessing taxpayer for 2006, 2007, 2008 and 2009 taxation years, Minister of National Revenue added amounts to income as shareholder appropriations totalling $512,211 and imposed gross negligence penalties — Whether Minister met burden to reassess beyond normal reassessment period — Whether Minister justified in imposing penalties for gross negligence — Whether lower courts erred in their reasoning and decision — Income Tax Act, R.S.C., 1985, c. 1 (5th Supp), ss. 152(4) and 163(2).

Summary

Case summaries are prepared by the Office of the Registrar of the Supreme Court of Canada (Law Branch). Please note that summaries are not provided to the Judges of the Court. They are placed on the Court file and website for information purposes only.

The taxpayer was assessed tax and penalties in respect of unreported income in the 2006, 2007, 2008 and 2009 taxation years. In reassessing him the Minister of National Revenue added amounts to income as shareholder appropriations totalling $512,211 and imposed gross negligence penalties.

The Tax Court dismissed the appeal from the reassessments. The Federal Court of Appeal dismissed the appeal.

Lower court rulings

March 20, 2023
Tax Court of Canada

2018-848(IT)G

Appeal from reassessments made under the Income Tax Act for the 2006, 2007, 2008 and 2009 taxation years was dismissed

June 7, 2024
Federal Court of Appeal

2024 FCA 107

Appeal dismissed.

Memorandums of argument on application for leave to appeal

The memorandums of argument on an application for leave to appeal will be posted here 30 days after leave to appeal has been granted unless they contain personal information, information that is subject to a publication ban, or any other information that is not part of the public record. You may also obtain copies of the memorandum by filing out the Request for Court records form or by contacting the Court’s Records Centre either by email at records-dossiers@scc-csc.ca or by telephone at 613‑996‑7933 or at 1‑888‑551‑1185.

If you have questions about a memorandum of argument or want to use a memorandum of argument, please contact the author of the memorandum of argument directly. Their name appears at the end of the memorandum of argument. The contact information for counsel is found in the “Counsel” tab of this page.

Downloadable PDFs

Not available

Factums on appeal

The factums of the appellant, the respondent and the intervener will be posted here at least 2 weeks before the hearing unless they contain personal information, information that is subject to a publication ban, or any other information that is not part of the public record. You may also obtain copies of factums by filling out the Request for Court records form or by contacting the Court’s Records Centre either by email at records-dossiers@scc-csc.ca or by telephone at 613‑996‑7933 or at 1‑888‑551‑1185.

If you have questions about a factum or want permission to use a factum, please contact the author of the factum directly. Their contact information appears on the first page of each factum.

Downloadable PDFs

Not available

Webcasts

Not available.

Date modified: 2025-08-30