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T-2, provides the following: 18.15(4)   Notwithstanding the provisions of the Act out of which an appeal arises, the Court, in hearing an appeal referred to in section 18, is not bound by any legal or technical rules of evidence in conducting a hearing for the purposes of that Act, and all appeal referred to in section 18 shall be dealt with by the Court as informally and expeditiously as the circumstances and considerations of fairness permit.   18.15(4)   Par dérogation à la loi habilitante, la Cour n’est pas liée par les règles de preuve lors de l’audition d’un appel interjeté en vertu de cette loi et visé à l’article 18; ces appels sont entendus d’une manière informelle et le plus rapidement possible, dans la mesure où les circonstances et l’équité le permettent ... Account Agreement In consideration of the acceptance of this account by Compagnie de Fiducie, M.R.S. ...

The matter of a statute bar to an assessment of costs would have been part of the consideration of the issue of a statute bar to bringing the motion itself and certainly was not part of the considerations in the motion decision resulting in dismissal of the motion. ...

Background [3]                When construction of the Property was approximately 60% completed, 27 Cardigan Inc. purchased 94 of the Units and 33 Cardigan Inc. purchased the remaining 93 Units from a related corporation for a total consideration of $10,544,000. [4]                The Property consisted of the Units, with parking, and some commercial space. ... Nikolaisen, [2002] 2 S.C.R. 235, the standard of review with respect to findings of fact is palpable or overriding error. [19]            In the course of his analysis, the Tax Court Judge did not refer to the decision of this Court in Malette, supra, where it was held that, in assessing the fair market value of 981 works of art by the same artist, which had been donated to a public gallery, a volume, or market absorption discount, had to be taken into account. [20]            The argument against the application of such a discount in that case was similar to the one adopted by the Tax Court Judge, i.e.: each work of art had to be valued individually, thereby precluding consideration of the other works of art coming onto the hypothetical market at the same time. [21]            Speaking for the Court, Noël J.A. rejected this argument, saying that volume or market absorption discounts were an accepted principle of valuation methodology. ...

Rule 409 does permit consideration of 400(3) factors on an assessment of costs, but even if I felt that this was a prudent expense in the circumstances of this case, the actual service falls within items 1- 26 and their associated limits of partial indemnity. ... The Appellants argued that counsel engaged here for the Quick Law research was an expert in her field and her specialized work, ie. considerations of implied versus constructive waivers necessitated by the actions of the Respondents, did not duplicate work performed by counsel of record. ...

In 1988, he transferred to the respondent title to a property for consideration of $1.00 and other good and valuable consideration. [4]                 By notice of assessment dated October 10, 1991, the Minister of National Revenue (Minister) assessed the respondent for the sum of $130,000 with respect to the property transferred to her by her husband. ...

No exhaustive list has been compiled and perhaps no exhaustive list can be compiled of considerations which are relevant in determining that question, nor can strict rules be laid down as to the relative weight which the various considerations should carry in particular cases. ...

The point remains, however, that the Court was asked to grant a declaration with respect to the constitutionality of key provisions of the ITA, and to do so in the absence of relevant considerations. ... This step inquires into whether the unequal treatment perpetuates stereotypes and prejudices, or whether it suggests that certain members of society are less worthy of consideration. ...

In light of such considerations, I fail to see how the applicant can assert that this was denied by the respondent. [13]         Admittedly income from marijuana was not pled in the Reply as an assumption, nonetheless the respondent referred to “Unreported Incomes” from business which included income from cocaine and income from marijuana. ... Apart from the letter relying on the wrong rule and causing confusion for all, this could have been raised and addressed during a trial management conference call that had been initiated by the Court (several days before that letter was sent) with a view to exploring the resolution of potential issues including considerations involving the scope of the expert report. [29]         Having clarified the letter during the hearing, applicant counsel then indicated that the contents of the respondent’s expert witness report would now be uncontested except for one document. ...

The trust assets included a property at 7 Austin Terrace, Toronto [the Property]. [5]                In December 1998, Evelyn Biles transferred her interest in the Property to herself and her daughter, Shirley Scott, as joint tenants for nil consideration. ... The Applicant argues that these words show that the Minister considered that an extension of time is only justified if CRA benefits – as if this type of consideration is a one-way street. [37]            The Applicant mischaracterizes the Minister’s words. ...

On that basis, the documentation and summaries related to credit card interest, books and gifts have been excluded from the Court’s consideration. ... Tax Year and Category Initial Alternative Assessment from Penalty Report Amount of Reduction of Income/ increase in Expenses Ultimate Amount of Unreported Income/ Disallowed Expenses Reported Business Income/ Expenses Percentage of Unreported to Reported Amount Percentage Decrease in Initial Assessment After Appeal 2010 Unreported Income $114,830.00 ($48,964.17) $65,865.63 $47,577.19   138% 43% 2010 Disallowed Expenses $17,297.00 ($7,121.82) $10,175.18 $18,806.55 54% 41% 2011 Unreported Income $43,011.00 Nil $43,011.00 $186,663.00 23% 0% 2011 Disallowed Expenses $166,685.00 ($122,528.79) $44,156.21 $168,752.00 26% 74% [45]         As always, the particular challenge for the Court arises in cases when the consideration of penalties occurs in the absence of knowledge or actual intent. ...