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., dated November 24, 1997, Judge Mogan considered the status of a person- Freeman Walters, the intervenor- who drove a truck for the appellant, a corporation carrying on business as a supplier to pizza restaurants. ...

The Respondent alleged that there was an agreement between the Appellant and his wife to the effect that all the assets were to be held in his wife's name for creditor proofing purposes and that at all times the Appellant considered the properties to be "owned by at least himself and his wife as 50/50". ...

Given that there was no such evidence and given that it is not my place to make a finding of forgery in the absence of such evidence, I do not base my decision on the apparent discrepancies in the signatures. [35]         Having considered the oral evidence, particularly that of Ms. ...

The consistency of a witness’s testimony with other known facts or probabilities can be considered. ...

11   In drawing the line between ordinary negligence or neglect and gross negligence a number of factors have to be considered. ...

The rule is that if a party has his suspicion aroused but then deliberately omits to make further inquiries because he wishes to remain in ignorance, he is deemed to have knowledge. [28]         It has been held that the concept of “wilful blindness” is applicable to tax cases and is included in the term “gross negligence” as that term is used in subsection 163(2) of the Act; see Villeneuve, above, and Panini, above, at paragraph 43. [29]         It has been held that in drawing the line between “ordinary” negligence or neglect and “gross” negligence, a number of factors have to be considered: (a)     the magnitude of the omission in relation to the income declared, (b)     the opportunity the taxpayer had to detect the error, (c)      the taxpayer’s education and apparent intelligence, (d)     genuine effort to comply. ...

The money that he paid on the StockLogics program was an investment and he received a return that was based on a business loss. [64]         Another factor to be considered is the anonymity of a tax preparer and a lack of acknowledgment in preparing returns. ...

The Queen, 2011 TCC 101: [14]   It is clear that an activity may be considered a commercial activity well in advance of the stage of profitability. ...

Therefore any consideration given at any time for the Property must be considered for purposes of subsection 160(1). ...

Taken any enforcement action against any of the MacNaughtons or their customers for GST purposes in relation to any of the tobacco products for which the Appellant has been reassessed. [26]         Paragraph 9 of the Fresh Reply states: With respect to paragraph 91 of the Amended Notice of Appeal, he states that the facts stated in that paragraph are not relevant to this appeal and are considered confidential information under the Excise Tax Act. ...