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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. ...

. … As noted in 1455257, a proceeding is instituted before the Tax Court by filing “[a]n originating document” as prescribed by the Tax Court of Canada Rules (General Procedure). Pursuant to the Tax Court of Canada Rules (General Procedure), an originating document means a document that is filed under section 21 of the Tax Court of Canada Act …. The only document filed by the Appellant under section 21 … was the Notice of Appeal, which was filed on May 26, 2017, a little more than a month after the corporation was dissolved. … Subsection 242(1) of the Manitoba CA does not allow a dissolved corporation to initiate a civil procedure. … ...

For example … there may be an interrelationship between the Appellant’s acquisition of the investment management services and its resupply of such services to the Pension Plans. … The Court cannot answer the Rule 58 Question … in a factual vacuum. ...

Such evidence must clearly establish that the “outsider” … has “effective” or “independent” management and control. … Ms. ...

In finding that this amount was deemed by s. 182 to include GST, Favreau J stated (at paras. 65-67, TaxInterpretations translation): [T]he conditions for the application of section 182 … are met in this case. There was a modification of an agreement for the making of a taxable supply in Canada to a person and an amount was paid to the registrant otherwise than as consideration for the supply. … Unfortunately for the appellant, the rules provided under paragraph 182(1)(b) … applied irrespective whether McKesson had claimed an input tax credit respecting the damages paid. ...

In addition to accepting their explanation of changed personal circumstances for the sale, Spiro J. noted (at paras. 34-35) that their professed intention of holding for the long term as their home was corroborated by their idiosyncratic choices in customizing the home’s details: … Rather than installing multiple televisions, the Appellants installed multiple fireplaces. This strongly suggests that they built the home only for themselves. … [T]he Appellants left nothing for a potential purchaser to customize. … The fact that the Appellants finished everything to their own personal taste strongly suggests that they built the home only for themselves. ...

Smith J found that the receipts invalid, stating (at paras 31, 32 and 45): … [A] receipt is a written document delivered in exchange for the receipt of money, goods or services, reflecting the actual amount of money or the fair market value of the property or services received. It follows that a document, though it bears the title “receipt” or “charitable receipt” …, may not be treated or accepted as such if it does not accurately reflect the money paid or the fair market value of the property or services actually provided in exchange. … [A]lthough the donation receipts in question are described as “official receipts” …, they are not in fact receipts as that term is ordinarily understood. ...

Katsikonouris, [1990] 2 S.C.R. 1029 …. See summary under Sched. V, Pt. II, s. 1 – home care service. ...

He further rejected Pangaea’s submission that, as it had disposed of its veto right, the exclusion from the definition for an agreement that disposes of the taxpayer’s property applied, stating (at para. 62): I find that there is no evidence of a conveyance or disposition of the Appellant’s veto right — even if it can properly be characterized as “property”. … [T]here was no evidence of an assignment of the veto right to a third party. ...