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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. ...

As far as the enterprise is concerned, the choice of proceeding by means of a contract of enterprise was made as a result of the economic and organizational requirements in connection with its operation in the Montreal region. ...

., the absence of any connection between these items of evidence and the Appellant's arguments make any conclusion favourable to the Appellant virtually impossible. ...

In Canada that confidentiality is required, in circumstances such as the present, by subsection 241(2) of the Income Tax Act which states that no official shall be required in connection with any legal proceedings to testify as to information obtained on behalf of the Minister for the purposes of the Act. ...

Penalties were imposed for the taxation years 1992, 1993, 1994 and 1995 in respect to the Appellant's understatement of his income in those years. [3]      The Appellant was also reassessed for GST for the reporting periods from September 1, 1991 through to August 31, 1995 in connection with the unreported business income arising out of the Minister's net worth assessment for this period. ...

His brother Michel never lived in the house, and it is alleged that he did not pay any money in connection with it. ...

    [43]     I have already dealt with the Appellant's responsibility regarding the collection and remittance of the GST in connection with the croupiers' services. ...

Everything he did was in connection with the business of the Appellant. ...

I find the majority of his work time was spent in connection with his employment activity. ...