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I find his payment for labour was for the supply of a service. [12]          Notwithstanding my finding that the cost of labour was in connection with the supply of a service, I wish to work through the sections dealing with the determination of the value of goods to satisfy myself the wording does not capture labour costs in this type of situation. ...

In computing income for the 1992 to 1995 taxation years the Appellant reported gross business income and deducted net business losses with respect to the business as follows: Year Gross Business Income Net Business Income (Losses) 1992 $ 785 ($9,038) 1993 $1,100 ($38,048) 1994 $9,884 ($45,490) 1995 $5,569 ($56,389) Originally the Appellant took the position that some of the expenses giving rise to the losses related to his acting as a real estate agent and some related to carrying on activities in his office in the basement of his home in connection with his employment with the Ontario Government. ...

"personal or living expenses" includes (a)            the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit. [13]          This point was not pursued in argument and was not mentioned in part C of the reply as one of the grounds relied on and in any event the notion that the expenses were personal or living expenses was thoroughly demolished. ...

In this regard, the appellant never made a single connection between a withdrawal and any gift. ...

They said clearly and unequivocally that they had no connection with the people at the centre of the scheme. ...

However, if the services or errands are recurring, frequent and performed or run by a majority of an employer's employees, this raises questions; even where those providing such services or running such errands characterize what they are doing as free and voluntary, as mutual aid volunteer work, as support or as an expression of solidarity with their co-workers, the fact remains that such conditions, circumstances and facts are hard to reconcile with a genuine contract of service, under which all work must be paid work. [19]          Although the evidence did not show any connection between the hour bank and the work done without pay outside the periods referred to in the records of employment, there is good reason to be sceptical, since it is fairly unusual for employees to agree to work for their employer without pay, especially if that employer never pays overtime. [20]          The appellant admitted that he had received envelopes containing cash, adding that the cash was payment for work and expenditures that had nothing to do with his employment. ...

And the last relevant paragraph is:                 From the moment of receipt of sixty thousand (60,000) Canadian Dollars all the financial connection and financial obligations between Bracha Amit (Achmed Fadila) and Zalman Amit will be terminated. [13]          Now, apparently, Achmed Fadila is the financial advisor of Ms. ...

Although he said he severed his connection with the Corporation after the spring of 1995 he continued to act on behalf of Albertan Homes Ltd. in relation to the GST corporate assessment and indeed he appeared on behalf of the Corporation as an agent before the Tax Court of Canada on September 28, 1998. ...

I do not find that high degree of negligence in connection with the misstatements of business income. ...

                (1) Where an individual is resident in Canada in a taxation year and, throughout any period of more than 6 consecutive months that commenced before the end of the year and included any part of the year (in this subsection referred to as the "qualifying period")                 (a) was employed by a person who was a specified employer, other than for the performance of services under a prescribed international development assistance program of the Government of Canada, and (b) performed all or substantially all the duties of the individual's employment outside Canada                 (i) in connection with a contract under which the specified employer carried on business outside Canada with respect to                 (A) the exploration for or exploitation of petroleum, natural gas, minerals or other similar resources,                 (B) any construction, installation, agricultural or engineering activity, or                 (C) any prescribed activity, or                 (ii) for the purpose of obtaining, on behalf of the specified employer, a contract to undertake any of the activities referred to in clause (i)(A), (B) or (C), there may be deducted, from the amount that would, but for this section, be the individual's tax payable under this Part for the year, an amount equal to... 122.3(1.1) Excluded Income. ...