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However, the absence of entries in the books of the Appellant's business, the lack of an acknowledgment of debt, and the overall context, including his mother's difficult financial situation, make the entire story of the $10,000 advance implausible, especially since the efforts to obtain the money would largely have stemmed from the financial needs of the Appellant's mother in connection with her restaurant, and since she would not ultimately have derived any benefit from what she borrowed. [17]     The Appellant's second argument is that he spent nothing on vacations. ...

In this connection, we must bear in mind the size of the amounts in question, the marked absence of supporting documentation and the Appellants' lack of administrative rigor. ...

In this connection, I believe that the following excerpts from Canada (Attorney General) v. ...

d)         My employer established my deadlines and priorities in connection with a contract awarded to him by the Canadian Space Agency.   ...

  [13]     As to integration, which is to be looked at from the point of view of the Worker, the evidence indicates that because of the advertising and the connections through the Conservatory and the works of administration for the teachers by the Conservatory I believe the integration test tends to point to a contract of service ...

  [27]     Further, though not maximizing profits at Vida, the worker, consistent with being in business on his or her own account generally, and not just in connection with Vida, could schedule the Vida versus the non-Vida massage therapy work to maximize profits at both. ...

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

It is therefore hard to make a connection between the company's needs in terms of a mechanic's services and the company's sales figures. ...

In assessing the appellant, the Minister disallowed an input tax credit ("ITC") in the amount of $12,600 that was claimed pursuant to section 169 of the Act, which reads as follows: Subdivision b- Input tax credits 169. (1) General rule for [input tax] credits- Subject to this Part, where a person acquires or imports property or a service or brings it into a participating province and, during a reporting period of the person during which the person is a registrant, tax in respect of the supply, importation or bringing in becomes payable by the person or is paid by the person without having become payable, the amount determined by the following formula is an input tax credit of the person in respect of the property or service for the period: A x B where A     is the tax in respect of the supply, importation or bringing in, as the case may be, that becomes payable by the person during the reporting period or that is paid by the person during the period without having become payable; and B     is                 (a) where the tax is deemed under subsection 202(4) to have been paid in respect of the property on the last day of a taxation year of the person, the extent (expressed as a percentage of the total use of the property in the course of commercial activities and businesses of the person during that taxation year) to which the person used the property in the course of commercial activities of the person during that taxation year,                 (b) where the property or service is acquired, imported or brought into the province, as the case may be, by the person for use in improving capital property of the person, the extent (expressed as a percentage) to which the person was using the capital property in the course of commercial activities of the person immediately after the capital property or a portion thereof was last acquired or imported by the person, and                 (c) in any other case, the extent (expressed as a percentage) to which the person acquired or imported the property or service or brought it into the participating province, as the case may be, for consumption, use or supply in the course of commercial activities of the person. [2]       The facts upon which the Minister relied in disallowing the ITC are stated in paragraph 4 of the Reply to the Notice of Appeal, which reads as follows: (a)         in February 1999, the Appellant purchased the [Piper Navajo] Aircraft for $180,000 plus $12,600 in GST; (b)         at all material times, the Appellant was inactive; (c)         at all material times, the Appellant did not carry out any business; (d)         except for the ITC of $12,600 claimed, the Appellant filed nil GST returns from September 1, 1997 to August 31, 2001; (e)         at all material times, the Appellant had no bank account; (f)          at all material times, the Appellant had no commercial activities. [3]      The respondent denied the ITC on the basis that, during the period at issue, the appellant was carrying on no commercial activity within the meaning of subsection 123(1) of the Act. [4]      A commercial activity is defined as follows in subsection 123(1): "commercial activity" of a person means (a) a business carried on by the person (other than a business carried on without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the business involves the making of exempt supplies by the person, (b) an adventure or concern of the person in the nature of trade (other than an adventure or concern engaged in without a reasonable expectation of profit by an individual, a personal trust or a partnership, all of the members of which are individuals), except to the extent to which the adventure or concern involves the making of exempt supplies by the person, and (c) the making of a supply (other than an exempt supply) by the person of real property of the person, including anything done by the person in the course of or in connection with the making of the supply. ...

However, when persons who are not dealing with each other at arm’s length decide to enter into a contract of employment, it becomes essential to make every effort to minimize the importance of the family connection. ...