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Cordoba actually paid the $250 amount to reduce that balance to the $4,500 amount, and certainly the documents he introduced do not reflect any "contra-account" which would be sufficient to be considered payment of that debt. ...

In my view the proposition of the appellant that this should be considered a "loan" is not viable. ...

If, however, as in the Kamloops case (supra), a limitation period may be adjusted as to when it commences based on the facts, this must be considered. ...

At the hearing the appellant’s agent produced copies of 1977 and 1978 tax returns which the Minister’s counsel agreed to forward to Revenue Canada asking that they be considered in relation to the arbitrary assessments. ...

It is also recognized that this Court has no jurisdiction at the present time to deal with the 1983 assessment and hence the only matter to be considered is the merit of the 1981 appeal. ...

For the Minister, the situation was simple — the appellant corporation had not succeeded in showing that the Minister was incorrect in accepting as “prima facie” evidence that the August 4, postage meter date stamp, and August 8 receipt of documents stamp were the essential ingredients to be considered — notwithstanding Mr Duncan's firm belief that he had complied with the Act. ...

Subsection 167(5) adds certain criteria to be considered stating that no order should be made under subsection (1) unless inter alia the application was brought as soon as circumstances permitted it to be brought. ...

Facts In 1973 the appellant, who was at that time married under the regime of community of property, sold certain properties to Overnite Express, and the respondent considered this to be a business transaction. ...

In essence there was no evidence: (1) that the parents had received any funds from the appellant; (2) there was no evidence that the parents were dependent upon the appellant by reason of mental or physical infirmity; (3) it appeared to the Presiding Member that the operation of a two-acre farm by the appellant’s parents seemed to indicate that they certainly were not in dire economic circumstances although the appellant indicated that the economic circumstance of his parents did not compare to Canada which, of course, in this case cannot be considered. ...

Furthermore, the amounts added by the respondent to each appellant, namely: (1) in 1974, $5,593; (2) in 1975, $19,901; (3) in 1976, $8,250; all are explained by: (1) the existence of cash money at the beginning of the period, namely the sale of the residence for $35,000, and the savings that both appellants had made on a certain period of time; (2) by the real estate transactions that could be considered as producing capital gain; (3) the nature of the amount of $9,930 as being money belonging to a third party; (4) the overstated personal and living expenses of $4,000; (5) the increase in the appellants’ assets by the physical work provided by Mr Henderson when he built his five cottages; this tremendous value of work is not taxable. ...