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Hughes & Co. Holdings Ltd., (1994), 94 D.T.C. 6511 (Fed. T.D.), is the only case that deals with the term “part- time employee”. ... This interpretation is in accordance with the definition found in the Dictionary of Canadian Law, Dukelow & Nuse, Carswell, referred to in R. v. ...

Rip” J.T.C.C. [1]           Toby Perry appealed his income tax assessments for 1989 and 1990 on the same basis as Stanley Kelley, Clare Smith and Dale Smith. ... His appeals are therefore dismissed with costs. [2]           In his submission, respondent’s counsel asked that no weight be given to Mr. ...

In the draft contract – Exhibit R-1- Blaney had intended to limit Butterfield to providing services exclusively to SDC during the term of the contract but that provision did not make it into the signed contract- Exhibit A-1. ... Pursuant to the paragraph 9(3) of the Tax Court of Canada Rules (E.I.) an intervener: "... may state in the notice of intervention that the intervener intends to rely on the reasons set out in the notice of appeal received by the intervener or the reasons set out in the notice of intervention of another intervener. ...

Subsection 280(1) of the Excise Tax Act (“the Act ”) provides: “280. (1) Subject to this section and section 281, where a person fails to remit or pay an amount to the Receiver General when required under this Part, the person shall pay on the amount not remitted or paid (a) a penalty of 6% per year, and (b) interest at the prescribed rate, computed for the period beginning on the first day following the day on or before which the amount was required to be remitted or paid and ending on the day the amount is remitted or paid.” [5] The onus is on the appellant to show that the reassessment is in error. ... It is sufficient for present purposes to reproduce these portions of B-074: “ Introduction This bulletin explains the guidelines for the reduction of penalty and interest in ‘wash transaction’ situations. ...

Reasons for Judgment Rowe, D.J.T.C.C. [1] The appellant- pursuant to section 261 of the Excise Tax Act (the " Act ")- applied for a rebate of Goods and Services Tax (GST) in the sum of $40,734.17 paid by him for the period commencing February 1, 1993 and ending January 31, 1997 on the basis it had been remitted by him, in error. ...

Paterson & Associates Ltd. ("Associates") who owned 50 per cent and Richard Gillard who owned 25 per cent. ... Paterson & Associates Ltd. ("Associates"). Paterson first participated in real estate ventures with Giuliani and Gillard in 1979 when they purchased an apartment building of approximately 100 units in Ottawa. ...

The second farm, “ Rockhurst” comprised 166 acres and was acquired in the name of a company called Rockhurst Farms Ltd., the shares of which were owned by the appellant's wife and his children. ... But he is a self-described workaholic and there is no doubt that his “ major preoccupation”, the term used in Moldowan, was farming. ...

The issue before me is not whether the appellant’s chief source of income during the years 1981 to 1986 was farming — counsel concedes it was not — but whether its chief source of income during this period was a combination of farming and selling groceries. ...

Tarantino tax returns of the appellant for the 1978-81 years and he agreed the business of Universal was described as "Mortgage Broker and Real Estate” or “ Broker, Sales, Real Estate" or "Management Consultant and Real Estate Broker”. ... Evidence of transactions of the sale and purchase of real estate by an appellant after the years under review in an appeal is admissible: Osler Hammond & Nanton Ltd. v. ...

MacDonald's opinion, the fair market value of the appellant's 60 acres on V-Day was as follows: 50 acres @ $500 per acre $25,000 10 acres @ $900 per acre $9,000 $34,000 When embarking on his appraisal, Mr. ...