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., Tab 12. [16] Document that the appellant gave to the auditor (transcript, page 179, lines 23 to 25). [17] For example, I have difficulty believing that Bruno Dompierre would have no recollection of events leading up to the purchase of the huts if he had been a co-owner (transcript, page 128, lines 18 to 24). [18] Particularly given that it is the lessee who undertakes to comply with clauses 5 to 8 of the lease, including clause 7, which provides that the lessee may not assign his rights or sublet. [19] Although the appellant asked the auditor whether he had considered the possibility that his two sons and he are all owners of the business, the auditor did not make any observations regarding this. [20] The conclusion reached in the rest of these reasons is that, except for a few relatively small changes, the Minister was correct in adding relatively significant amounts to the appellant’s income.   ...

This represented 7.5% of the total funds raised of $2.2 million and the Minister considered that 7.5% was a reasonable financing cost. ...

As for the place of work, it cannot be considered in the traditional way because the work must be performed where the clients are. ...

Because I have determined that the purported transfer of the farm was invalid and legally ineffective, section 245 need not be considered. [42] Respecting whether there was a "disposition" of the farm to his parents in August, 1992, the Appellant stated that the transaction was a valid disposition of land effected by the execution and delivery of prescribed Form I under the Ontario Land Registration Reform Act. ...

If they made a mistake, it was a reasonable mistake that cannot be considered to be neglect or carelessness on their part. ...

This is authority for the view that payments required under a previous agreement and continued under a new agreement can, for the purposes of subparagraph (b)(ii) of the definition of "commencement day", properly be considered payable under the earlier agreement. ...

(d)             for greater certainty, no other activity, including working, housekeeping or a social or recreational activity, shall be considered as a basic activity of daily living. [6]              Section 118.3 of the Act lists three requirements to claim a disability tax credit: a)              The individual must have a severe and prolonged mental or physical impairment; b)             The effects of the impairment are such that his ability to perform a basic activity of daily living is markedly restricted; c)              He must provide a doctor's certificate certifying 1 and 2. ...

However, the onus is on the appellant to show that a donation of property or objects was indeed made and that the amount indicated on the receipt represents the fair market value of that property. [30]          This Court has, on a number of occasions, considered the matter of the factors that are essential to the existence of a donation. ...

These examples should not be considered as exhaustive. On the one hand, the term "artiste" clearly includes the stage performer, film actor, actor (including for instance a former sportsman) in a television commercial. ...

I must therefore conclude that, when considered in the social, political and legal context of the claim, the age distinctions in sections 118.5 and 118.6 of the Act are not discriminatory. [43]      Given the finding that the impugned legislative provisions do not infringe subsection 15(1) of the Charter, it is not necessary to turn to section 1 of the Charter. [44]      In the circumstances, I must therefore dismiss the appeal. ...