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These factors require consideration of the purpose of a project. The questions set out in paragraphs 1 and 4 can be reformulated as follows: Did the taxpayer use standard procedures or methods to carry out the work in the taxpayer’s field of activity? ...

The establishment and development of Northwood Farm followed substantial consultation, a consideration of the risks involved followed by the investment of reasonable amounts of capital. ...

Only by a careful consideration of all of the evidence presented in Court, some of which may not have been available to the Auditor, nor counsel for the Respondent, could these outstanding issues be resolved. ...

In fact, consideration of such a centre was remarkably shortlived since construction of the golf course commenced in 1989 and all of the farm facilities and stables (but one) were bulldozed. ...

Finally, the appellant criticizes the TCC judge for not having taken into consideration the evidence in the record showing that the appellant’s Canadian customers, to be able to submit an order to the appellant for contact lenses for the treatment or correction of a defect of vision, must have a Prescription because those customers must provide the appellant with specialized biometric information that can normally only be found on a Prescription. [6] For her part, the Minister conceded at the hearing that Section 9 does not go as far as stating that the supplier must absolutely obtain and keep a copy of the Prescription; however, she submits that this provision requires, at the very least, that reasonable evidence be provided of the Prescription’s existence, which, according to the Minister, the appellant failed to do because the evidence that it submitted in this regard was strictly speculative. ...

In consideration of $4,000,000 paid to A Ltd, the taxpayer obtained certain rights and privileges to produce and take petroleum substances from lands from which it was already entitled to receive gas. ...

Simply because the CITT declined to consider the issue of “reason to believe” in the context of “value for duty” in an earlier instance, does not mean the CITT going forward has foreclosed consideration of issues like those raised here by MoC. [52] As the Federal Court of Appeal has opined in the past, “[t]he function of the CITT as both an adjudicator of disputes and an instrument in the development of trade and import policy suggests that the Parliament intends and expects the CITT to take into account, even in appeals under section 68 of the Customs Act, policy questions that are not appropriate for ordinary judicial appeals”: Deputy Canada (Minister of National Revenue) v Yves Ponroy Canada, 2000 CanLII 15801 (FCA) at para 33. [53] To paraphrase (now) Associate Judge Milczynski, MoC seemingly is at an early stage of the Act ’s adjudicative process. ...

The taxpayer, in his pleadings, alleges the July 10, 1964 documents are against public policy and public morality and “void of legal effect by reason of illegality of consideration and by reason of undue influence and duress”. ...

Finally, a broader consideration moves me to the conclusion to which I would come. ...

As was stated in Cameco at para 41, “whether questions posed in the course of an audit might have direct or collateral consequences on ongoing or prospective litigation is not a relevant discretionary consideration.” [92] Justice Rowe of the Supreme Court of Canada, writing for the majority in Law Society of Saskatchewan v Abrametz, 2022 SCC 29, states at para 36 that the primary focus of the doctrine of abuse of process in the context of administrative law is “the integrity of the courts’ adjudicative functions, and less on the interest of the parties […] The proper administration of justice and ensuring fairness are central to the doctrine […] It aims to prevent unfairness by precluding ‘abuse of the decision-making process.’” [93] In this case, the Minister acted within the powers conferred to her by the ITA. ...