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Sloan is redundant. [6]               In exercising my discretion under section 119 of the Rules to direct an examination prior to the hearing of the appeal for the purpose of having the person’s testimony available to be tendered as evidence at the hearing, I must take into account:   (a) the convenience of the person whom the party seeks to examine, (b) the possibility that the person will be unavailable to testify at the hearing by reason of death, infirmity or sickness, (c) the possibility that the person will be beyond the jurisdiction of the Court at the time of the hearing, (d) the expense of bringing the person to the hearing, (e) whether the witness ought to give evidence in person at the hearing, and (f) any other relevant consideration. [7]               In addition, I must be satisfied that the Respondent has met the tests for commission evidence which have been applied by the courts. ...

With respect, I do not consider this to be a material consideration. Invariably, when one of the litigants in a civil action is self-represented, there is a substantially increased burden not only upon the remaining parties but upon the court. ...

The appellant is appealing the assessment on the basis that he did make instalment payments in 2001 on account of his income tax liability for the 2001 taxation year and that the interest and penalty assessed by the Canada Revenue Agency ("CRA") were thus improperly assessed as the CRA did not take the instalment payments made in 2001 into consideration. ...

  [3]               The appellant brought a motion before this Court to be disposed of without appearance by the parties and upon consideration of written representations, under subsection 69(1) of the Tax Court of Canada Rules (General Procedure) (the Rules) ...

  [6]               Subsections 325(1), (2) and (3) of the ETA read as follows:   325. (1) Tax liability re transfers not at arm’s length ‑  Where at any time a person transfers property, either directly or indirectly, by means of a trust or by any other means, to   (a) the transferor’s spouse or common-law partner or an individual who has since become the transferor’s spouse or common-law partner,   (b) an individual who was under eighteen years of age, or   (c) another person with whom the transferor was not dealing at arm’s length,   the transferee and transferor are jointly and severally liable to pay under this Part an amount equal to the lesser of   (d) the amount determined by the formula   A- B   where   A         is the amount, if any, by which the fair market value of the property at that time exceeds the fair market value at that time of the consideration given by the transferee for the transfer of the property, and   B         is the amount, if any, by which the amount assessed the transferee under subsection 160(2) of the Income Tax Act in respect of the property exceeds the amount paid by the transferor in respect of the amount so assessed, and   (e) the total of all amounts each of which is   (i)                   an amount that the transferor is liable to pay or remit under this Part for the reporting period of the transferor that includes that time or any preceding reporting period of the transferor, or   (ii)                 interest or penalty for which the transferor is liable as of that time,   but nothing in this subsection limits the liability of the transferor under any provision of this Part ...

At the request of the succession of Louise Benoit (the succession), the company redeemed the 33 common shares held by Louise Benoit for a consideration of a demand note for $1,514,616. ...

There was a claim for a delivery expense on the 2006 return but no claim for the other expenses listed in paragraph 11 above. [13]          The gross business income reported by the Appellant was $58,570.73, $31,884.63, $29,296.83 and $36,840.43 in 2006, 2007, 2008 and 2009 respectively. [14]          After a complete review of the Appellant’s income tax returns and a consideration of her evidence, I have concluded that the Appellant has introduced sufficient evidence to establish on a balance of probabilities that the amounts reported in her 2005 income tax return do not relate to her business. ...

The Court also said that, given the complexity and detail of the Income Tax Act, in normal circumstances greater weight will be placed on a textual analysis of the provision under consideration.   ...

Thus, the Applicant had 90 days from that date in which to file the application currently under consideration by the Court. ...

  [27]     When giving consideration to tools, i t is important to identify the business that the contractor operates. ...