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  [1]               This appeal concerns the deductibility of expenses incurred by Cyrus Driver in 2003 and 2004 in connection with a restaurant business operated by him in Saudi Arabia. ...

  [10]     Was the Appellant sincere when he testified that he had wanted all the steps and actions taken in connection with his file to be cancelled? ...

In so assessing the Appellant and confirming the Assessments, the Minister made the same assumptions of fact as follows: (a)         the Appellant was incorporated under the laws of Saskatchewan as a business corporation; (b)         the Appellant registered for the purposes of the Excise Tax Act (the "ETA") and was a registrant at all relevant times; (c)         during the Relevant Period the Appellant provided individuals, eligible by virtue of a Saskatchewan Government program known as "the Self Employment Program", with instruction, training and support to develop, implement and operate viable businesses ("educational services"); (d)         in connection with the educational services the Appellant also provided equipment, materials and supplies ("technology and supplies"); (e)         the Appellant received consideration from individuals participating in the Self Employment Program for the educational services and the associated technology and supplies of $132,281.40 and $12,701.60 respectively; (f)          the educational services and the technology and supplies provided to the individuals were taxable at 7%; (g)         the Appellant was required to collect tax on its supply of educational services and associated technology and supplies of $9,259.70 and $889.11 respectively for a total amount of $10,148.81; (h)         in filing its GST return for the Relevant Period the Appellant failed to report the tax collectible referred to in the previous subparagraph. ...

(b)        During the taxation years in issue, the Appellant reported the following net business losses:   Description 2000 2001 2002         Gross income  $144,558  $268,297  $7,495         (Expenses) ($160,951) ($293,000) ($9,930)         (NET LOSSES)  ($16,393)   ($24,703)  ($2,435)   (c)        The amounts set out in the previous subparagraph were claimed by the Appellant in connection with activities involving the purchase and sale of shares on the stock market.   ...

Ravagnolo's matter in connection with both matters.   [12]   The third point of contention is the costs of the [TRANSLATION] "Partial transcription of the recording of the hearing of December 2 and December 3, 1999 ($673.67)". ...

ANALYSIS [7]            In the Reply to the Notice of Appeal the Respondent agrees to a number of items including the following: (a)            as a Sales Associate of FSL the Appellant was employed in connection with the selling of property or negotiation of contracts at stores operated by FSL in Winnipeg, Edmonton and Langley; (b)            the Appellant was required to work away from the ordinary place of business of FSL to carry out competition shopping, attend training sessions and other meetings and provide service calls to customers as required; (c)            the Appellant was remunerated by FSL in whole or in part by commissions; (d)            under his contract of employment with FSL the Appellant was required to pay for his own automobile expenses plus "supplies" and "other expenses". [8]            During the hearing of the appeals counsel for the Respondent filed a document prepared by FSL. ...

See also s. 139(1) (ae) of the Income Tax Act which includes as "personal and living expenses" and therefore not deductible for tax purposes, the expenses of properties maintained by the taxpayer for his own use and benefit, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit. ...

The contract between the Government and the Comité local de développement provided the following:          -         Number of hours per week        :          40          -         Hourly wage                    :          $7          -         Subsidy rate                             :          100 percent          -         Duration of employment            :          20 weeks [21]     The employment contract of the interested parties was subsequently improved when the salary was increased by $1.93 an hour, as a result of another labour support program. [22]     The evidence adduced by the appellant did not show on the balance of evidence that an agreement to increase the number of hours had been made in connection with the contract entered into between the parties, which contract stipulated 40 hours. [23]     The explanations provided neither justified nor supported the appellant's claims, particularly since she admitted that her claims had been strongly influenced by her wish to see her employment insurance situation improved. [24]     Consequently, the evidence does not justify the Court's intervention. ...

For the purposes of this appeal its principal provision is paragraph 5 which reads as follows:                 Commencing May 1st, 1995 Bob shall pay to Karen for the support of the children the sum of $300.00 per child bi-weekly (total $600.00 bi-weekly) payable in the case of each child until the earliest of the following times: (a)            the child becomes 18 years of age and ceases to be in full time attendance at the educational institution (normal vacations and work periods in connection with school are not to be interpreted as ceasing to be in full time attendance at school). ...

       [21]          Nevertheless, I find that employed physicians had a closer connection to the Centre, and were subject to more control. ...