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The Appellant's testimony cannot be considered reliable in the circumstances ...

Other facts that have been considered are:  -          October 1, 2004, the business known as “ Huron Tax Consultants” was sold to Huron Tax Consultants Inc. of which you are a shareholder.-          January 17, 2005 a request was made to adjust your and your spouse’s 1999 to 2003 income tax returns to treat the business income as a proprietorship and include all the income in your spouse’s returns.-           April 6, 2005 assignment in bankruptcy was filed by your spouse.   ...

It is unconscionable to many that in order to have a business license, citizens are forced to become something considered sinful in the eyes of God. ...

According to the Appellant, when he would resume his business activities in the spring, he would use the remainder of that amount to start the activities;   (l)   The Appellant also told the auditor for the Canada Revenue Agency that he did not receive insurance benefits during the taxation years in issue except for the amount paid to him for damages suffered in an accident involving one of his motor vehicles;   (m) A net worth method audit revealed that the Appellant omitted to report the business income amounts of $54,856, $40,544 and $49,423 for the 2001, 2002 and 2003 taxation years, respectively (see Appendices I to III of this Reply which should be considered to be an integral part of this paragraph).   12. ...

  [14]     It would be a considerable stretch to say that just because the Dell contract is a lease and has certain similarities, that therefore the Future Shop Contract must be considered a lease even though it is called a sale ...

Kerr's analysis of typewriter imprints cannot be considered reliable. [24]Next Mr. ...

To sum up, the new owners were aware of the content of the Deed of Sale between 152817 and Trisud and acted in such a manner that they could not be considered as having assumed any liability with regard to the balance of the purchase price. ...

I have considered the evidence as a whole and concluded that it is not sufficient for me to draw this conclusion. ...

That the alleged partnership must be considered in the totality of the circumstances prevents the mechanical application of a checklist or a test with more precisely defined parameters. [18]     Application of the Facts (a)       There was no written documentation, or other documentation, to indicate that it was intended that the Company be a partner in Horns Peak. ...

(admitted)       12    In making a reassessment concerning the 1999 taxation year on December 15, 2003, outside the normal assessment period, and in confirming it, the Minister of National Revenue considered the following facts:   (a)        The facts set out in subparagraphs 10(a) through (o) above. ...