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The periods at issue in his appeal are those referred to above in connection with the payer’s appeal numbered 97-231(UI), which concerns Jeannot Lamothe's employment. [8] In each of the six appeals, the decision by the Minister of National Revenue (Minister) with respect to each worker’s employment states that the worker did not hold insurable employment because there was no genuine contract of service between the payer and the person whose employment is at issue. ...

(page 385) If previous statements constitute more a policy statement or an observation arising from a policy which the tribunal or a member of the tribunal believes follows from the legislation, no reasonable fear of prejudice results, even if a connection can clearly be made between those statements and the issue before the tribunal. ...

The Appellant therefore succeeds on issue 1, on issue 2, which is consequential on it, and on issue 6. the capital losses [8] The capital losses that the Appellant claims to have suffered in the 1988 and 1989 taxation years are said to arise from certain investments in real estate made by him in the United States; specifically, from payments made as a result of certain loan guarantees given by him in connection with those investments. ...

We have it on high authority that there is no reason why there should be any connection between farming and another source of income with which it is combined to create a chief source of income. ...

During the winter of 1989-90, he saw an advertisement in the paper placed by George Tkach- the appellant- requiring an interested person to contact him in connection with helping work a market garden/farm. ...

Additional provisions of the Agreement are described below in connection with the promissory note given under the fifth joint venture. [11] The document continued with a number of responsibilities and operations required of the co-venturer. ...

The company and its salespersons didn’t need neither telephones nor internet connection – as decided by disallowing Telephone and Communication Expenses.  ...

H, in connection with the Minister’s arguments under 247(2)(a) and (c), I’d like you to tell me for each transaction involving the purchase and sale of uranium between Cameco Europe SA and Comeco Corporation or Cameco Europe, Ltd and Comeco Corporation taking place between 1999 and 2003, I’d like you to tell me which terms and conditions differ from those which would have been made between persons dealing at arm’s length, and what you say the terms and conditions of each of these transactions would have been had they been entered into between persons dealing at arm’s length. [26]         The answer for all the related questions above was as follows: The Crown’s primary position is in this appeal is that the structure is a sham. ...

“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. [63]         In this case, during the periods at issue, the appellants were in the process of starting up their business. ...

These are refinements offered to the tenants in connection with the occupation of suites and, in most instances, are also property for the use of which, along with the suites themselves, rent is paid. ...