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In my opinion, it may now be taken as established that the fact that a person has entered into only one transaction of the kind under consideration has no bearing on the question whether it was an adventure in the nature of trade. ...

The income of the appellant’s spouse must be taken into consideration. ...

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.” ...

As such, he is bound by his motivations and his conduct. (2), the Property was acquired to be renovated and sold. (3), the appellant’s husband was in the renovating business. (4), the financing was short term in nature and was of a high ratio basis. (5), the whole transaction was conducted in a very professional and business-like manner. (6), the period of acquisition, renovation and eventual disposition was short. (7), the borrowings required collateral security from the appellant and her husband by way of wage assignments from the husband’s business; that is, in relation to the CUNA borrowings. (8), the appellant’s husband had a history of other property transactions. (9), I conclude that the appellant and her husband both contributed work and skill to the project, although, albeit, not in equal proportions. (10), in consideration of the intention, the course of conduct, the ownership, time/lenghth, the work and skill expended, the financial arrangements lead this court to the conclusion that the appellant’s partnership share from the sale of the property was income from a business; that 1s, on income account. ...

Pawar, as has been identified in those cases before this Court; the two year deadline is still relevant as is the nature of the subsisting assessment under consideration: Ahmad v. ...

In light of that fact, it is difficult to discern any possible prejudice to the Appellant. [6] Parliament’s intention is best reflected in subsection 18.15(3) of the TCC Act: 18.15(3) 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. [7] Subsection 18.15(1) of the TCC Act. [8] Subsection 18.17(1) of the TCC Act. [9] Subsection 18.22(1) of the TCC Act. [10] The Minister’s only obligation is to serve the Reply by registered mail within five days of its filing as described in footnote 5 above. ...

Information redacted under paragraph 21(1)(b) of ATIA [41] Paragraph 21(1)(b) of the ATIA states: 21(1) The head of a government institution may refuse to disclose any record requested under this Part that contains (a) advice or recommendations developed by or for a government institution or a minister of the Crown, (b) an account of consultations or deliberations in which directors, officers or employees of a government institution, a minister of the Crown or the staff of a minister participate, (c) positions or plans developed for the purpose of negotiations carried on or to be carried on by or on behalf of the Government of Canada and considerations relating thereto, or (d) plans relating to the management of personnel or the administration of a government institution that have not yet been put into operation. ...

Justice Cameron stated, at page 1141: After giving the matter the most careful consideration, I have come to the conclusion that in every appeal … regarding a re-assessment …. which is based on fraud or misrepresentation, the burden of proof lies on the Minister to first establish to the satisfaction of the Court that the taxpayer … has “made any misrepresentation….” unless the taxpayer in the pleadings or in his Notice of Appeal…or at the hearing of the appeal has admitted such misrepresentation or fraud. ...

The purchase price was in consideration of the sum of $150,000. [8] On March 8, 2008, the appellant entered into a one-year lease agreement with Mr. ...

The appellant may adduce facts constituting a prima facie case which remains unanswered; but in considering whether this has been done it is important not to forget, if it be so, that the facts are, in a special degree if not exclusively, within the appellant’s cognizance; although this last is a consideration which for obvious reasons, must not be pressed too far. 5. ...