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Issues [5]      There are six issues involved, namely: (i)       Whether income from the Activity constitutes income from a business or income from property; (ii)       If I find that it is income from a business, then was there a valid election filed in accordance with subsection 249.1(4) of the Income Tax Act (the " Act ")?; ... Both letters asked the following three questions: 1.        The names and addresses of each of your tenants. 2.        ... 3.        For what periods during each year was each cottage rented? The answer to these three questions was never provided to the CCRA or to the Court. [79]     The CCRA sent a letter to Lorna, dated August 4, 2002. ...

The Queen, 2002 GTC 244; and Lau v. The Queen, 2003 GTC 527 at Tabs 16, 17 and 18 in support of his position that the appeal should be allowed with costs and the assessments vacated. ... The Queen, 2002 CarswellNat 3256 (F.C.A.) and Wheeliker v. The Queen, 1999 CarswellNat 417 (F.C.A.) at page 9: It being recognized in this instance that the respondents acted as directors, in conformity with the will of the shareholders, I see no reason why they should be allowed to assert their lack of qualification to escape the liability cast upon directors by virtue of setion 227.1 of the ITA. [190]    There were facts elicited in evidence which support the position of the Appellant as a director. ... The Queen, 2002 CarswellNat 91 (T.C.C.) at page 19.... It is another to be preternaturally artless in accepting assurances under circumstances where the root cause for the inquiry has never been properly addressed. ...

Joncas et frères           $15,000                                      0 153760 Canada Inc ... Translation certified true on this 28th day of February 2002. [OFFICIAL ENGLISH TRANSLATION] Erich Klein, Revisor [OFFICIAL ENGLISH TRANSLATION] 98-1096(IT)G BETWEEN: PAUL-AIMÉ JONCAS, Appellant, and HER MAJESTY THE QUEEN, Respondent. ... Translation certified true on this 28th day of February 2002. Erich Klein, Revisor [1]     In the transcript of the appellant's testimony, the date given is December 18, 1992. ...

On or about July 8, 2002, the Minister issued a notice of confirmation disallowing Mr. ... The Evidence:           Ruben Corvalan [4]      The Appellant was born in Chile and moved to Canada in 1974. ... Note 11:    See P.W. Hogg, J.E. Magee, "Principles of Canadian Income Tax Law", 2d ed. 1997, para. 16.3(b). 21         The Tax Court judge was mindful of the difficulty of the task he was about to embark on.     ...

By the reassessments, the Minister included gross business income in the amounts of $23,272.50 and $18,347.84 respectively, allowed expenses in the amounts of $10,957.69 and $11,442.19 respectively, assessed unreported net business income in the amounts of $12,314.81 and $6,905.65 respectively, and imposed penalties pursuant to subsection 163(2) of the Income Tax Act (" Act ") in the amounts of $783 and $348.50 respectively. [2]      In further reassessing the Appellant pursuant to subsection 165(3) of the Act for the 1996 and 1997 taxation years, concurrent Notices of Reassessment thereof dated July 11, 2002, the Minister allowed deduction of additional rental expenses in the amount of $1,500 for each of the 1996 and 1997 taxation years and correspondingly reduced the gross negligence penalties by the amounts of $124.10 and $123.10 respectively. [3]      The Minister took the position that any amount of expenses claimed by the Appellant in excess of the amounts of $12,457.69 and $12,942.19 for the years 1996 and 1997 respectively, were not made or incurred for the purpose of earning income and that they were personal or living expenses. [4]      The Appellant took the position that the expenses claimed in excess of the amounts allowed by the Minister in the 1996 and 1997 taxation years were made or incurred by the Appellant to earn income from a business. ... Argument of the Respondent [55]     Counsel said there were three issues: 1.        ... This was not so. [74]     Under section 230 of the Act, the taxpayer is required to keep adequate records. ...

The assumptions of fact relied upon by the Minister total 51 and are as follows: (a)         The Appellant operated a podiatry business; (b)              the Appellant operated out of a foot clinic (hereinafter "the Clinic"); (c)               the Appellant advertised and obtained the clients (hereinafter "the Clients"); (d)              the Worker was hired as a podiatrist and her duties included foot treatment, nail surgery, manufacturing orthotics and some receptionist duties; (e)               the Appellant originally hired the Worker for an indefinite period of time; (f)                the Appellant and the Worker did not enter into a written contract; (g)               the Worker provided her services to the Appellant's existing Clients and walk-in patients; (h)               the Worker performed the majority of her services at the Appellant's premises (the Clinic); (i)                 the Worker also did house calls at the Clients' premises; (j)                 the Worker was paid solely by commissions; (k)               the Worker earned set commission rates as follows: 50% of fees for office appointments             70% of fees for house calls             17% of fees for orthotics (l)                 the Appellant determined the Worker's wage rates; (m)            the Appellant determined the rates charged to the Clients; (n)               the Appellant paid the Worker on a monthly basis; (o)              the Worker did not bid for work; (p)              the Appellant controlled all Client fees; (q)              the Appellant calculated the Worker's earnings and prepared an invoice for the Worker; (r)                the Appellant's normal office hours were as follows: Monday to Friday          9:00AM to 5:00PM Saturday                        9:00AM to 1:00PM (s)               the Worker worked full-time for the Appellant; (t)                 the Worker normally worked the following hours: Monday, Tuesday          9:00AM/10:00AM to 5:00PM/6:00PM Wednesday                   Noon to 7:00PM Thursday, Friday           9:00AM/10:00AM to 5:00PM/6:00PM (u)               the Appellant determined the Worker's hours and days of work; (v)               the Worker's hours were dependent on the Clients' appointments; (w)             the Appellant provided a receptionist who handled Client appointment bookings; (x)               the Appellant retained the right to control the Worker; (y)               the Worker was hired for her experience and expertise; (z)               the Worker was not supervised because she was a professional; (aa)           the Worker was required to report to the Clinic; (bb)         the Appellant assigned Clients to the Worker; (cc)          the Appellant also assigned walk-in patients to the Worker; (dd)         the Appellant monitored the Worker's performance through Clients' response; (ee)           the Worker covered other doctor's patients when the doctor was unavailable; (ff)             the Worker represented the Appellant while performing her services; (gg)          the Worker's name was listed on the Clinic door and in the Appellant's advertising; (hh)          the Clients were the Appellant's; (ii)               the Clients' records belonged to the Appellant; (jj)        the Worker did not work for others while performing services for the Appellant; (kk)       the Worker did not solicit her own clients; (ll)         the Worker could not hire her own helpers or replace herself; (mm)    the Worker was not free to come and go as she please when appointments were booked; (nn)      the Appellant provided all of the tools and equipment required including a furnished work location, support staff and orthotics manufacturing equipment; (oo)      the Worker provided her own vehicle; (pp)      the Worker did not have a capital investment in the business; (qq)      the Appellant paid all operating expenses of the Clinic; (rr)       the Appellant provided all of the materials and supplies required; (ss)       the Worker incurred expenses for her own vehicle, podiatrist license and liability insurance; (tt)        the Worker did not rent tools or equipment from the Appellant nor did she pay for receptionist services; (uu)      the Worker did not have a chance of profit or risk of loss; (vv)      the Worker did not have her own business name; (ww)    the Worker was not operating her own business while performing services for the Appellant; (xx)      the Appellant originally agreed to provide employment for the Worker in conjunction with her immigration from Britain to Canada, and (yy)      a condition of the Worker coming to Canada was that she would have full-time employment. ... She married in 2002 and did not want the immigration process impaired by working for the clinic prior to obtaining the work visa. ... Redband. [16]     Dr. Warden clarified the following assumptions of facts: (f)       she stated that she requested a contract at the outset and was refused; (h)      the work performed at the clinic was under the direction of the Appellant, using the clinic's equipment and products with patient appointments booked by Natalie Rodriguez; (m)     she clarified Mr. ...

AND FURTHER the appeal in respect of the 20 09 taxation year is dismissed and the penalties imposed shall remain.     ... Jarvis, 2002 SCC 73 highlighted the obligations of taxpayers and well as the penalties to ensure taxpayers feel so obliged to comply: 49   Every person resident in Canada during a given taxation year is obligated to pay tax on his or her taxable income, as computed under rules prescribed by the Act (ITA, s. 2 …). ... Drouin Deputy Attorney General of Canada Ottawa, Canada     ...

In addition, the shareholder who had originally contributed the land to Valley was having health problems and his children, who were looking after his affairs, had begun making all communications through their lawyer. [24]         Valley continued to lose money after the asset sale but, in October 2002, an unsolicited buyer bought Valley’s assets. ... Graham DATE OF JUDGMENT: June 5, 2014   APPEARANCES:   Counsel for the Appellant: Kenneth J. ... (see Exhibit R-2, Tab 18). [13]          Exhibit A-3, Tab 4. [14]          Exhibit A-3, Tab 2, page 2. [15]          Exhibit A-1, Tab 2. ...

MacPhee” MacPhee J.   Docket: 2021-1574(IT)G BETWEEN: JOEL DE LAS ALAS, Appellant, and HIS MAJESTY THE KING, Respondent.   ... Appendix A                                                               CITATION: 2023 TCC 164 COURT FILE NO.: 2021-1574(IT)G 2021-1544(IT)G STYLE OF CAUSE: JOEL DE LAS ALAS v. ... The Queen, 2019 FCA 299 at para 60. [31] Crane, supra note   NOTEREF_Ref152158422 \h   \* MERGEFORMAT 14 08D0C9EA79F9BACE118C8200AA004BA90B02000000080000000E0000005F005200650066003100350032003100350038003400320032000000 at paras 24-25, 30, 44; Berg, supra note   NOTEREF_Ref152158968 \h   \* MERGEFORMAT 10 08D0C9EA79F9BACE118C8200AA004BA90B02000000080000000E0000005F005200650066003100350032003100350038003900360038000000 at paras 28-29. [32] Berg, supra note   NOTEREF_Ref152158968 \h   \* MERGEFORMAT 10 08D0C9EA79F9BACE118C8200AA004BA90B02000000080000000E0000005F005200650066003100350032003100350038003900360038000000 at para 28. ...

New subsection 248(30) of the Act, which applies in respect of transfers of property after December 20, 2002 to qualified donees (such as registered charities), allows the opportunity to rebut this presumption. ... I will address this position first. [413]      In Stewart v. Canada, 2002 SCC 46, [2002] 2 S.C.R. 645 (“ Stewart ”), the Supreme Court of Canada stated at paragraph 68: With respect to whether or not an anticipated capital gain should be included in assessing whether the taxpayer has a reasonable expectation of profit, we reiterate that the expected profitability of a venture is but one factor to consider in assessing whether the taxpayer’s activity evidences a sufficient level of commerciality to be considered either a business or a property source of income. ... Canada, 2002 SCC 47, [2002] 2 S.C.R. 684 at paragraph 22. [324] See, also, paragraphs 29 to 31 of Will-Kare Paving & Contracting Ltd. v. ...