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  [22]     I have considered the one difference in the case at hand from the two cited cases. ...

Bains produced a cheque or money order, or bank draft, no wages were considered paid. ...

Flanagan could not be considered to be an employee of Domart Energy.   [32]     In short, Grubbs Oilfield Services was an independent business operated by Mr.  ...

In planning the layout for Stonecroft, the Appellant said she considered the fact that her boyfriend Rodney Phillips would be moving in with her, and modified the plans to accommodate Mr. ...

Only part of the supporting documentation relating to purchases made by the appellant in the operation of his business was made available to the Minister. [1]   [3]      The appellant declared the following gross revenues and net revenues from the operation of his business during the relevant period:     1997 1998 1999 2000 Gross revenue Nil [2] $130,906 [3] $54,560 [4] $7,540 [5] Net revenue Nil $23,661 ($11,358) $7,540   [4]      In the absence of the necessary information, the audit of the appellant’s sales was based, as a last resort, on the bank deposits made to the appellant’s only bank account. [6]   [5]      Thus, using these bank statements, the Minister compiled all of the appellant’s deposits for each year of the relevant period and rightly deducted from the deposits all of the amounts that cannot be considered to represent sales, such as loans and rebates. ...

I am equally hesitant to attempt to reconcile this Court’s position on the alternative approaches taken to situations where a rectification remedy has been considered. ...

  [21]     The Court also considered in Pepper and Mymryk the constructive receipt provisions of subsection 56(2) of the Income Tax Act. ...

  [28]     Therefore, the evidence as a whole contains too many contradictions, uncertainties and unanswered questions, such as how the business operated when the Appellant was not working there, to allow me to conclude that the Minister's decision is unreasonable in the circumstances and in light of all the factors to be considered. ...

In my view, the Appellant failed to understand the distinct personality a corporation has apart from shareholders at law, and has also failed to recognize that the Workers are to be evaluated as individuals and not as a unit when considered in their separate legal roles as employees ...

The Queen, 94  DTC  1735, Rip J. of this Court allowed the appellant's appeal, concluding that the amounts paid to a babysitter for the seven-day period immediately preceding the appellant's return to work should be considered to be child care expenses. ...