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  [17]     While all four guidelines indicate that Raymer was an employee during the period in question there are other relevant considerations in assessing the total relationship between the parties ...

Conclusion [29]     Subsection 165(1) of the Act provides that every recipient of a taxable supply made in Canada shall pay Her Majesty in Right of Canada tax in respect of the supply calculated at the rate of 7 percent on the value of the consideration for the supply. ...

  [19]     Determining whether an employment is insurable is a difficult matter requiring that many factors be taken into consideration. ...

The appellant neither collected nor remitted the applicable GST on the value of the consideration for the goods and services supplied to his tenants. [31]     Subparagraphs 9(j), (k), (m) and (n) of the Reply to the Notice of Appeal read as follows: [TRANSLATION] (j)          during the period in issue, the appellant claimed all taxes paid or payable in respect of the building as input tax credits (ITCs), whereas he could only claim 75 percent, and the difference of 25 percent was therefore assessed in his hands; (k)         the appellant claimed an ITC in respect of 100    percent of his personal telephone line expenses, but the auditor reduced it to 25 percent since the appellant used his line for business only when the office facsimile was in operation; (l)          50 percent of the ITCs claimed in respect of entertainment expenses were allowed; (m)        the appellant keeps what may be characterized as summary accounting records; (n)         the appellant wrongly believed that he could separate his various income sources in order to qualify as a "small supplier"; [32]     The appellant brought no material evidence in support of the soundness of his appeal. ...

" partnership, in which the appellants were the sole partners on a 50‑50 basis, acquired the buildings for consideration that reflected the deteriorated condition of the premises but also a high vacancy rate ...

He acknowledged that health and welfare benefits are added to the union hourly rate but these benefits were not included in the consideration he received from his wife ...

(ii)         a loss from the disposition of a debt or other right to receive an amount, unless the debt or right, as the case may be, was acquired for the purpose of gaining or producing income from a business or property (other than exempt income) or as consideration for the disposition of capital property to a person with whom the taxpayer was dealing at arm's length,... is nil. [15]       Unlike paragraph 20(1)(c) this section only requires a single stage inquiry, namely what was the purpose for acquiring the debt. ...

The Minister assessed for that taxation year by virtue of which the Appellant's business expenses were reduced by the amount of $23,507. [6]      Subsequent to receiving the Notices for the six years in issue, the Appellant served Notices of Objection on the Minister and after due consideration, by Notices dated October 3, 2001, the Minister further reassessed her pursuant to subsection 165(3) of the Act to allow additional business expenses in each of the taxation years, reduced business income for the 1995 taxation year and deleted employment income and increased the gross business income for the 1996, 1997 and 1998 taxation years, respectively. [7]      The issues in all of the years under appeal are: (a)       Is the Appellant entitled to deduct expenses in excess of the amounts allowed by the Minister for the taxation years at issue? ...

A number of considerations would seem to point in that direction. In 1993 a former revenue assessor was retained to assist with the GST requirements. ...

(admitted)   (f)         The Appellant set his own hours of work and his pay without taking into consideration the actual time worked.  ...