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The Court was able to observe from numerous photos that the project was an ambitious one, well structured and well directed. [3] The appellant also described his future projects and his plans for a possible expansion, adding that this dispute had held up their implementation. [4] As to the validity of his appeal, he contended that, at the relevant time, more than 90 percent of his building converted to a bed and breakfast was intended for clients. [5] He noted in this connection that the areas occupied exclusively by his live-in partner and he were very small, and maintained that virtually all the areas and rooms fitted up on the three floors had been designed and developed for the well-being and comfort of clients. [6] To support and substantiate his assessment of things, the appellant said that, at the start of the project, he had even lived with his live-in partner in a tent during the summer on the lot next to the bed and breakfast in order to accommodate clients and maximize his project's profitability. [7] In her capacity as monitoring officer for the Fédération des agricotours du Québec, Odile Bélanger visited the premises. ...

Tax planning had then been done in connection with the setup of the structure. [6] Robert Houle explained that he and his two colleagues worked in the insurance field; he himself was very specifically involved in administering and managing a staff of about 20 people. [7] The other two were basically responsible for insurance, one in the agricultural field and the other in the commercial field. ...

Profit and loss: [15] Saunders had a chance of profit and risk of loss in connection with her arts projects if revenues either exceeded or fell below expenses. ...

They were directors in law only because of their family connection to Eugene Fitzgerald. ...

Therefore, I am satisfied that the Crown has met its initial burden with respect to the amounts owed by the Appellant in connection with her husband’s Part I liability. [13]         Ms.  ...

The Facts [6]      On the 16 th day of June 2000, the Canada Customs and Revenue Agency ("the Agency") assessed the applicant $155, 245.82 under section 160 of the Act in connection with a transaction between the applicant and her husband which occurred on November 8 th, 1995. ...

Section 44.19 of the Excise Tax Act, 1970, supra reads as follows:                   44.19 (1) Where tax under Part III, IV, or V has been paid in respect of any goods and Her Majesty in right of a province has purchased or imported the goods for any purpose other than                                (a)      resale,                                (b) use by any board, commission, railway, public utility, university, manufactory, company or agency owned, controlled or operated by the government of the province or under the authority of the legislature or the lieutenant governor in council of the province, or                                (c)      use by Her Majesty in that right, or by any agents or servants of Her Majesty in that right, in connection with the manufacture or production of goods or use for other commercial or mercantile purposes,                           an amount equal to the amount of that tax shall, subject to this Part, be paid either to Her Majesty in that right or to the importer, transferee, manufacturer, producer, wholesaler, jobber or other dealer, as the case may require, if Her Majesty or the dealer applies therefor within two years after Her Majesty purchased or imported the goods.                   ...

MacLauchlan had important political connections upon which he might rely, and those statements, unfounded in Mr. ...

In this connection, the Court of Quebec judgment is not relevant.   [13] In conclusion, it is not the role of the judge reviewing a jeopardy collection order to rule on the legality of a notice of assessment. ...

Justice Barnes BETWEEN: LAWRENCE LEMIEUX Applicant and THE MINISTER OF NATIONAL REVENUE Respondent JUDGMENT AND REASONS UPON hearing this application for judicial review at Edmonton, Alberta on June 8, 2016; AND UPON reviewing the materials filed with the Court and hearing counsel on behalf of the Respondent and the Applicant in person; AND UPON reserving decision; AND UPON concluding that this application should be allowed for the following reasons: [1]                This application arises from the Respondent’s refusal to grant discretionary relief to the Applicant, Lawrence Lemieux, from the imposition of a repeat late filing penalty of $4,745.87. [2]                The record discloses that the Respondent granted relief from penalties and interest imposed in connection with Mr.  ...