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In filing her 2004 income tax return, the appellant considered the $65,000 to be non-taxable life insurance proceeds. ...

Moreover, where the judge considered the absence of documentary evidence to be problematic, he clearly explained the basis for his concerns and the reasons why he believed such documentation reasonably ought to have existed. ...

In so doing, she considered the evidence of the appellant’s witness, Mr. ...

  [5]                The Tax Court Judge found that in the criminal proceedings the Manitoba courts had refused to order further disclosure of material by the Crown, including material seized by the CRA which Mr Golden now has in his possession and says should be considered in the tax appeals. ...

However, they should have been expressly considered in the judge’s determination and in my view they were not ...

Having considered the Crown’s written and oral submissions, we are not persuaded that Mr. ...

  [5]                In finding the payments to be income from a source the Judge considered and rejected the appellant's argument that the payments were a windfall.  ...

  [10]            Contrary to the appellant’s counsel, I do not believe however that, based on the workers’ failure to intervene regarding their status, the judge inferred that the workers considered themselves to be employees or that their silence was an expression of their intention with regard to the legal status of their employment. ...

  [2]                First of all, in detailed and meticulous reasons in support of the impugned conclusions, the judge ruled that the loss claimed by the appellant could not be considered a business investment loss within the meaning of paragraph 39(1)(c) of the Income Tax Act (“Act”). ...

)   [6]                To reach this finding of fact, the judge considered that the appellants did not testify, did not have the so-called third director testify, and simply submitted documentary evidence concerning the allocation of the company’s shares among the three shareholders, that is, themselves and Jean-Claude Leblanc ...