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After consideration, the Minister issued concurrent Notices of Reassessment mailed on March 17, 1994 which had the effect of allowing capital losses in the amounts of $1,030 and $25,708, respectively. 7. ...

Despite the sympathy which I feel for this family I cannot offer relief based on considerations which are not relevant under the statute. ...

After consideration, the Minister issued reassessments for the 1990 and 1991 taxation years which had the effect of allowing Mr. ...

Giving consideration to all of the facts, I find that the appellant was not employed by Stephen Kape Industries Inc. and did not receive a salary or wages within the meaning of the Act from the Stephen Kape Industries Inc. ...

Taking into consideration the evidence before me, the submissions and case law, although the matter is not free from doubt, I am satisfied that the better view is that the appellant has succeeded in his burden. ...

I therefore conclude that the appellants had lived apart since May 29, 1990 and that the Minister must reassess accordingly, taking also into consideration the admissions of the appellants in respect of certain false statements made in their respective returns as mentioned above. ...

Ed Delisle (the "transferor") transferred cash in the amount of $10,000 (the "property") to the appellant; (c) the transferor is the son of the appellant and as such the transferor and the appellant were not dealing at arm’s length; (d) at the time of transfer, the fair market value of the consideration given by the appellant for the property was zero; (e) the aggregate of all amounts that the transferor was liable to pay under the Act in or in respect of the taxation year in which the property was transferred or any preceding taxation year was at least $26,671.18. ...

Analysis The consideration here is whether or not the applicant should be excluded from the time limitations otherwise imposed on him because he did not receive actual notices of the confirmation. ...

Before I discuss the two bases upon which the respondents challenge the validity of my order of August 9, 1993, I should mention some of the information and considerations which satisfied me that the order was justified. ...

Lastly, counsel for the respondent indicated to the Court that the appellant's failure to testify at the hearing had to be taken into consideration. ...