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Consideration of the scheme shows that, though the client gains or loses by fluctuations of the market, the appellant neither gains nor loses on interests that are outstanding in the hands of clients, though the appellant is affected by market fluctuations in securities that are merely passive in the appellant’s hands and are not the subject of any transaction at the time. ...

After giving careful thought to the wording of the subsection, I am unable to see that there is any such ambiguity in the wording of the section as to justify resort to the discussions in Parliament at the time when consideration was being given to the legislation. ...

Before giving consideration to the matters raised on this appeal, it should be added that counsel for the parties agreed that this information respecting the shareholders in these three companies should be submitted as follows: “ (1) The Saskatchewan company—the shareholders are— 40% to S. ...

This objective is reflected in subsection 18.15(3) of the Tax Court of Canada Act, which applies to employment insurance appeals. [3] It reads: Notwithstanding the provisions of the Act under which the appeal arises, the Court is not bound by any legal or technical rules of evidence in conducting a hearing and the appeal shall be dealt with by the Court as informally and expeditiously as the circumstances and considerations of fairness permit. [9] Most unrepresented parties have great difficulty in dealing with a motion in writing. [10] Given the objectives of the procedure, it is not generally appropriate to proceed by a motion in writing in employment insurance appeals where the Appellant is not represented by counsel. [4] I am satisfied that in this case it is appropriate to hold a hearing. [11] Before concluding, I would draw to the attention of the Appellant that, in the Respondent’s written representations, at paragraphs 14 and 15 in Part III, the Respondent takes the position that this Court has no jurisdiction and that the matter belongs in the Federal Court. ...

Decision Based on Written Representations [3] The Respondent asked that the Motion be disposed of in writing upon consideration of written representations from the parties and without the parties having to appear in Court. [4] Under section 69 of the Tax Court of Canada Rules (General Procedure), the Appellant had 20 days to either file and serve written representations in opposition to the Motion or file and serve a written request for a hearing. ...

A consideration of all the evidence and of the authorities and dictionary definitions to which we were referred, brings me to the conclusion that neither in technical terms nor in common speech nor in that of those who deal in such products would the skin of a mature merino sheep with the wool or hair attached to it be described as a fur. ...

Argument Cases presented to the Board for consideration, and to which reference was made by both parties, were as follows: Christopher John Goodman v MNR, 8 Tax ABC 320; 53 DTC 225; Herman Luks (No 2) v MNR, [1958] CTC 345; 58 DTC 1194; William Robert Martyn v MNR, 35 Tax ABC 428; 64 DTC 461; Norman Lusby Goodwin v MNR, [1971] Tax ABC 42; 71 DTC 67; William H. ...

In this case, there were no such unusual circumstances which would warrant consideration since nothing beyond the taxpayer’s direct control had been involved. ...

Funds to allow for a minimum level of existence, either as the sole source or in augmenting other income of the relatives, prima facie, should deserve consideration for the deduction permitted. ...

As to the failure to give notice of a constitutional issue under section 57 of the Federal Court Act, there are practical considerations to be taken into account. ...