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In filing her income tax return for the 1994 taxation year, the Appellant reported total income before deductions in the amount of $183,840, calculated as follows: Employment Income $ 65,000 Interest and other investment income 28,840 Business Income 90,000 $183,840 The business income of $90,000 represented a management fee paid to the Appellant by Holdings. ...

If this section were to apply to the present appellant, as suggested by the respondent, she would be paying a tax of close to $70,000 (or $69,860.03) as hereinafter set down instead of an amount of $55,057.12 according to the appellant or $51,067.27 if she was living in the Province of Ontario, as hereunder set down: Federal tax of $16,280.69 Provincial tax of $ 4,225.78 US tax of $30,560.80 $51,067.27 According to the calculations of the appellant, the latter should pay a tax of $55,057.12 on a taxable income of $97,487.47: Federal tax Satin Nil Provincial tax ches cha $24,497.32 US tax $30,560.80 $55,057.12 She would, according to the respondent, on a taxable income of $97,487.47 pay a tax of $69,860.03: Federal tax $14,801.91 Provincial tax $24,497.32 US tax $30,560.80 $69,860.03 Counsel for the appellant says that the latter is not trying to avoid or lessen her tax liabilities on the income she has received. ...

Year Income Losses 1990 0 $57,283.29 199] $1 1,793.38 $71,103.00 1992 $12,275.22 $53,607.78 1993 $43,705.56 $58,319.64 1994 $ 7,347.47 $36,715.55 1995 $21,722.90 $27,067.95 1996 $1 1,594.24 $21,312.68 In 1995 Mr. ...

It was established that losses and relevant figures were as follows: Taxation Year Gross Income Expenses Net Income (Loss) 1988 nil $17,719 ($17,719) 1989 $15,144 $43,821 ($28,377) 1990 $22,973 $64,109 ($41,136) 1991 $ 7,227 $39,232 ($32,005) 1992 nil $60,927 ($60,927) 1993 nil $51,450 ($51,450) The Appellant was also asked questions, on cross-examination on two occasions, respecting why he did not get rid of the boat. ...

Pursuant to paragraph 7 of the agreement, the appellant had no control over any amendment to the terms and conditions of the mortgage provided Clarfield agreed to any change sought by Gooden and participants representing at least 51 % interest in the loan to Gooden also agreed that such change, alteration, modification or variation be made. ...

At the same time, Budney requested the appellant to participate in a business corporation known as Affordable Tire & Auto Repair Ltd. ...

At 11 % interest, an increased expense of $6,600 is very close to the loss reported in each of the three years. ...

Appeals allowed. 1 At all relevant times, the Appellant was employed under contract by the province of On tario to assist in the production of various publications, etc. and appears to have worked at the offices of various Ministries. 2 A TD-1 form is generally provided to an employee by an employer to be completed for the purpose of providing the employee’s basic personal tax exemptions and other relevant infor mation to permit the employer to properly calculate the source deductions to be submitted to Revenue Canada. 3 Exhibit R-2. 4 ^he amounts referred to are those listed in the Appellant’s Exhibit A-4. 5 > Sheffield v. ...

. /?., [1998] 2 C.T.C. 2832 (T.C.C.), a decision of my colleague Bowman, at paragraph 18, in the factual background, he said:...Ms. ...

When the appellant and Musseau went into partnership it was under the name of W & M Company and business was carried on pursuant to a written partnership agreement. ...