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In determining the reasonableness of the amount claimed by the employee for travel costs, consideration will be given to the mode of transportation used by the employee versus the mode of transportation that could be used to satisfy the requirement to travel. [19] In her written argument, counsel for the respondent submitted the following: [TRANSLATION] 36. ...

Specifically, the dimensions or size of data collections, for which the collection costs qualify, should agree with the requirements that can be determined from well-established statistical considerations for developing good experimental designs. [14] Counsel for the Respondent referred to the decision of Judge Sarchuk of this Court, in Sass Manufacturing Limited v. ...

Fundamental to an equal protection defense to prosecution is "proof that the decision to prosecute was based on impermissible considerations such as race, religion, or the desire to penalize the exercise of constitutional rights. ...

Such testimony will have to be precise and complete, making it possible to understand and prove the fact that the increase in the value of their assets does not result from the commercial activity that generates their usual income or from some other activity. [26] An account whose essential components are set out in a vague or even confused way, with the time at which transactions occurred not being ascertainable in a sufficiently precise manner and with substantial consideration being paid in cash and without it being possible to know the names of the parties to the transactions, certainly cannot be the basis for satisfactory and persuasive evidence. [27] The appellant had a great deal of time to prepare his case and should have been able to give clear, precise and detailed testimony; yet his memory failed him and he was unable to provide a minimum level of explanations; what is more, he denied certain significant facts even though they had been disclosed in writing by his own accountant. [28] To illustrate the poor quality of the appellant’s testimony, I consider it helpful to note that he even said that he did not remember or was unaware of the existence of a $10,000 note he signed on December 27, 1990, in favour of his spouse, Suzanne Brunet (Exhibit I-12). ...

E-15, as amended reads as follows: "(1) Subject to this Part, every recipient of a taxable supply made in Canada shall pay to Her Majesty in right of Canada a tax in respect of the supply calculated at the rate of 7% on the value of the consideration for the supply. ...

The testimony of the Appellant and his brother Platon was based on their memory of what happened in the three years at issue and, understandably, it was mostly vague and incomplete rather than reliable. [14]     Taking into consideration all of the circumstances, including the testimony of the Appellant, his brother and Revenue Canada auditor, the admissions and documentary evidence provided by the Respondent in the light of the well established case law, I am satisfied that the Appellant has failed in his onus of establishing on a balance of probabilities that the Minister was ill-founded in fact and in law in his reassessment. [15]     Accordingly the appeal is dismissed. ...

Whether during the football season or outside of it there would be weeks during which the claimant would not receive any money because the times at which his salary instalments were paid to him depended upon the football schedule and not on other timing considerations. ...

The essential clauses of this Transaction are set out hereinafter: RECEIPT, FULL AND FINAL MUTUAL RELEASE AND TRANSACTION In consideration of the payment of the sum of ONE HUNDRED AND THIRTY EIGHT THOUSAND DOLLARS ($138,000.00) in capital and interest by Defendant/Cross-Plaintiff The Great-West Life Assurance Company (hereinafter referred to as " GREAT-WEST "), that the Plaintiff/Cross-Defendant Russell E. ...

In making such a determination, consideration will be given to the nature of the business and the individual's involvement in the day-to-day operation of that business. ...

The Appellant claims that it acquired certain foreign exchange contracts for the purpose of earning a profit and then transferred part of those contracts to Company A and the remainder to Company B in consideration for common shares and the assumption by each subsidiary of certain obligations connected with the foreign exchange contracts. 3. ...