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Based upon the position of the Crown that any rights in the treaties are "subject to regulation" by the Crown through the unilateral enactment of legislation, the further right to "friendship and protection" must be included in a consideration of the rights at stake in this case. ...

In determining wilful blindness, consideration must be given to the education and experience of the taxpayer. d.         ...

After careful consideration of all of the Respondent’s evidence regarding the circumstances of the false statement made by the Appellant in the 2008 Adjustment Request, I am of the view that the burden on the Respondent established by subsection 163(3) of the ITA has been satisfied. [82]         In particular, the Appellant’s signing and filing of the 2008 Adjustment Request in the circumstances disclosed by the evidence tendered by the Respondent represents a marked and substantial departure from the conduct of a reasonable person in the same circumstances and constitutes gross negligence as described in Venne. ...

First, as stated in subsection 163(3) of the Act, the burden of establishing the facts justifying the assessment of the penalty is on the Minister. [11]         It is also recognized that each case must be considered on its own merits and that the facts must be given careful consideration by the Court to determine whether the Minister was able to meet his burden of proof. [12]         During oral argument, counsel for the Minister did not argue that the two taxpayers knowingly made a false statement or omission in their returns. ...

(Bermuda) in consideration for loans advanced by the Appellant; Garmeco International Consulting Engineers S.A.L. ...

Grondin received the $148,000 amount in question; (d)              that amount came from the monies accumulated in his pension fund that he had transferred to an RRSP of which he was the annuitant. [12]         Absent any other considerations, it is obvious that those amounts must be included in Mr. ...

For a trial Judge to say "I believe him because I judge him to be telling the truth", is to come to a conclusion on consideration of only half the problem. ...

For example, at one point the appellant learned that a number of students who were studying French as a second language had expressed a desire to learn expressions used in Quebec so as to better communicate with their colleagues and the appellant supplied some material with Quebec expressions to the teachers of French as a second language and asked them to use it. [43] [150]     This last example was a decision resulting from a request by students rather than by the CBC, which was paying for the service, but it was still an externally driven instruction rather than an internally driven one originating with the appellant. [151]     Another consideration regarding control is the fact that the appellant has no office or permanent staff outside Montreal, but some of the teachers for the CBC contract, such as Dalia El Mourad who taught in Toronto, were outside of the Montreal region. ...

Moreover, these estimates described the details of the type of work the sub-contractor in question was to perform and the consideration that would be received for the work performed. ...

.); ex parte Hooper ((1926) 37 C.L.R. 368 at 373): An 'assessment' is not a piece of paper; it is an official act or operation; it is the Commissioner's ascertainment, on consideration of all relevant circumstances, including sometimes his own opinion, of the amount of tax chargeable to a given taxpayer. ...