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. … He played poker non-recreationally for the purpose of making a profit. He organized his life around poker. … The appellant's poker playing activities were his main source of income during the years in dispute. … [T]he Appellant spent almost all of his time playing poker. An analysis of FullTiltPoker and PokerStars records revealed that the Appellant frequented these online poker sites on a near-daily basis and frequented one of the two gambling sites, often both sites, for … an average of 274 days per year. … Despite his unusual lifestyle and his propensity for always wanting to play at the high-stakes tables, the appellant was a serious businessman. … He avoided playing against certain opponents and he adjusted his play to his bankroll to avoid overly perilous situations. ...

After referring (at para. 9) to an “administrative difference in treatment between land and shares,” Bowman CJ stated (at paras. 10-11, 13): It may well be that … Irrigation Industries … is seen as justifying a different treatment of shares in the context of the concept of "adventure in the nature of trade" (the meaning of which was authoritatively determined … [in] Taylor …as approved … in Irrigation Industries Ltd.). I think there is a more mundane reason and it is two-fold: (a) The Minister has pragmatically recognized that if he started aggressively taxing share transactions he would be forced to recognize losses on the same basis; (b) a vigorous campaign to tax share trading profits with its concomitant recognition of losses would certainly be administratively burdensome and costly without any certainty of any net advantage to the fisc. … [A] concerted commercial activity of buying and selling shares over an extended period of time can more appropriately be described as the carrying on of a business in the ordinary sense of that word without resort to the concept of "adventure in the nature of trade". … Here the volume of trades, the rapidity of turnover and the appellant's own testimony that he was buying and selling shares to realize a profit indicate that the concerted activity of the appellant was clearly the carrying on of a business. ...

. … … [T]he translated documents provided by Mr. Tang do not require this Court to exercise any discretion since these documents already meet the requirements set out by Rule 89. … The list of documents clearly indicated that some of Mr. ... The Minister was made aware of the translation issue prior to the hearing. … [A]n opportunity to examine Mr. Tang’s translator would, without expert evidence or an alternative translation, have had no impact on the admissibility of the translated documents. … ...

In confirming the imposition of gross negligence penalties, Campbell J. stated (at para 21): [The taxpayer] … has several degrees from well-recognized educational institutions. He has a varied work experience, which included providing investment, tax and financial advice as an insurance agent and mutual funds agent. … [H]e recognized that the status of payments had the potential of changing from non-taxable to taxable. … The unreported tips were very significant and material when compared to the income that he reported in these taxation years. … [W]ith his background …, at the very least he should have …made some effort to ascertain the proper tax treatment of such large gratuity amounts. ...

Masse DJ nonetheless found that the taxpayer was carrying on business, stating (at para. 40): … He certainly could demonstrate better business practices and I note that his record keeping leaves much to be desired but I still conclude that he conducted his activities with a level of commerciality sufficient to constitute a business. …. His ventures have seen prior successes and he … is continuing to pursue similar opportunities in hopes of repeating his prior success. Although the taxpayer’s expenses were only documented in his spreadsheets (he did not provide any invoices, receipts etc.), Masse DJ allowed a significant portion of the claimed expenses – but disallowed others, for example, only allowing the expenses of the taxpayer’s cell phone but not his two land lines (stating, at para. 47, that “it is more reasonable to dedicate one telephone for … for business use.”) ...

The King, 2022 TCC 7-- summary under Subparagraph 40(2)(g)(ii) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(2)- Paragraph 40(2)(g)- Subparagraph 40(2)(g)(ii) maintaining rental income could be a good s. 40(2)(g)(ii) purpose The appellant, a non-testamentary discretionary trust, made non-interest bearing loans to two companies (“Roseau” and “Spec”) which were owned, directly or indirectly, by its sole trustee and by another family trust – but it had not direct or indirect shareholding in those companies. In finding that s. 40(2)(g)(ii) precluded the recognition of a business investment loss when the two companies became insolvent and were placed into receivership, St-Hilaire J stated (at para. 25, TaxInterpretations translation): Contrary to the circumstances of the Byram case … in this case the appellant trust had no "legitimate expectation of dividend income" since it is not a shareholder of Roseau and Spec or any other company in the group of companies listed in the organizational chart …. Regarding a submission that the loans were made in order to preserve a source of rental income, she stated (at para. 29): I agree with … [Scott] that subparagraph 40(2)(g)(ii) … should not be interpreted more strictly than Parliament intended. ...

II, s. 9 (which requires inter alia that the contract lenses “are, or are to be, supplied under the authority of a prescription prepared … by [a qualified practitioner] for the treatment or correction of a defect of vision,” Smith J stated (at para. 69, TaxInterpretations translation): [I]t is not sufficient … that the appellant's website inform the consumer of the need for a valid prescription. The appellant must itself obtain a copy of the prescription … from which it can be concluded that the consumer has a prescription "for the treatment or correction of a defect of vision." Before so concluding, and after having referred to s. 286(1), he stated (at paras. 65-66): This Court has repeatedly pronounced on the obligation to maintain records in relation to zero-rated supplies …. ...

Miller J stated (at paras 25, 29-30): … [T]he Appellant assumed liability for small dents or scrapes to the vehicles he was delivering. ... The services offered by Canadian Auto are indistinguishable from “driving services” in this regard. … I have concluded that a “freight transportation service” means a particular service of carrying personal property from one place to another. … [T]here must be [a] mode of carrying the personal property. … [T]he vehicle cannot be both the personal property and the means of carrying it at the same time. … Canadian Auto [instead] provided a driving service to the insurance companies and the owners of the vehicles. ...

In my view none of the exhibits to MP’s affidavit … can reasonably be construed as being such a certificate or true copy of the relevant portion thereof.... … I cannot find that CRA’s “special mail services request form”, albeit presumably with a Canada Post “tracking number” stamped or affixed thereon, can reasonably be considered, “the post office certificate of registration of the letter or a true copy of the relevant portion thereof” per subsection 335(1). Thus subsection 335(1) has not been complied with. … My second concern is that in the July 31, 2017 Canada Post email to MP …, the Canada Post Customer Service Team identifies the missing registered letter as, “... this Registered Letter mailed May 24/17 to Raad Murad.”… It is [the Appellant] that is the entity to which registered mail … was to have been sent. ... He also noted (at para. 24) that proof of the sending of the Notice of Confirmation by registered mail could have been “by the Respondent calling one or more witnesses to provide viva voce evidence based on personal knowledge” – but this was not done. ...

". … [T]here is no expert evidence as to the value of the Courseware at the time it was donated by the Appellant. … … GLS created a significant market for the multimedia courseware in much the same way as markets were created for art prints in Klotz and Nash. ...