Date: 20190625 Docket: A-171-16 Citation: 2019 FCA 191 CORAM: GAUTHIER J.A. STRATAS J.A. LASKIN J.A. BETWEEN: MICHAEL DAVIES Appellant and HER MAJESTY THE QUEEN Respondent Heard at Toronto, Ontario, on June 25, 2019. Judgment delivered from the Bench at Toronto, Ontario, on June 25, 2019. REASONS FOR JUDGMENT OF THE COURT BY: STRATAS J.A. Date: 20190625 Docket: A-171-16 Citation: 2019 FCA 191 CORAM: GAUTHIER J.A. STRATAS J.A. LASKIN J.A. BETWEEN: MICHAEL DAVIES Appellant and HER MAJESTY THE QUEEN Respondent REASONS FOR JUDGMENT OF THE COURT (Delivered from the Bench at Toronto, Ontario, on June 25, 2019).

STRATAS J.A. [ 1 ] The appellant appeals from the order dated February 6, 2016 of the Tax Court of Canada ( per Bocock J.): 2016 TCC 104 . [ 2 ] The Tax Court did not err in law or commit any palpable and overriding error. Indeed, we substantially agree with the findings of law and mixed fact and law in the reasons of the Tax Court. [ 3 ] Therefore, we will dismiss the appeal with costs fixed by agreement in the amount of $2,500, all-inclusive. "David Stratas" J.A. FEDERAL COURT OF APPEAL NAMES OF COUNSEL AND SOLICITORS OF RECORD Docket: A-171-16 APPEAL FROM AN ORDER OF THE HONOURABLE MR. JUSTICE R.S.

BOCOCK DATED APRIL 27, 2016, DOCKET NOS. 2010-3571(IT)G AND 2014-2450(IT)G STYLE OF CAUSE: MICHAEL DAVIES v. HER MAJESTY THE QUEEN PLACE OF HEARING: Toronto, Ontario DATE OF HEARING: June 25, 2019 REASONS FOR JUDGMENT OF THE COURT BY: GAUTHIER J.A. STRATAS J.A. LASKIN J.A. DELIVERED FROM THE BENCH BY: STRATAS J.A. APPEARANCES : Arthur Birnbaum FOR THE APPELLANT Carol Calabrese For The Respondent

SOLICITORS OF RECORD : Birnbaum Law Barrister and Solicitor For The Appellant Nathalie G. Drouin Deputy Attorney General of Canada For The Respondent