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Although Respondent's counsel suggested that he should have retained the services of a lawyer, that cannot seriously be considered a probability — perhaps not even a possibility in the Appellant's situation. 10 The Appellant exercised precisely the degree of care, diligence and skill to prevent the failure that a reasonably prudent person would have exercised in comparable circumstances — namely, none. 11 Accordingly, the appeal is allowed with costs. ...

His estimate assigned most of the vehicle expenses to its use for professional purposes. 8 The procedure followed by the Department in making the various valuations was carried out entirely in keeping with standard practice and the result was thus unexceptionable: the respondent analyzed and examined the case very impartially and gave great attention and consideration to the appellant's often arbitrary claims. 9 When he was audited, the appellant was able to submit any comments, supply any documents, and lastly, benefit from the advice of an accountant to support and flesh out his claims. 10 The assertions to the effect that the Department could not, as regards his building, go back beyond the prescription period are absurd and have no basis: the purpose of the concept of depreciation requires that periods well beyond the short prescription period be considered, especially where buildings are concerned. 11 The appellant did not discharge the burden of proof upon him: on the contrary, the evidence showed among other things that his valuations were arbitrary and totally unjustified. ...

Conclusion 24 The appeal is allowed with costs on the basis that the sum of $23,593 should be considered in computing the UCC. ...

Suspicious circumstances, therefore, will more often lead to closer scrutiny than those that are in no way suspect. 11 The courts have further considered another test as to whether there is a carrying-on of business. ...

That as long as the children are attending a post-secondary institute or attending a vocational school in pursuit of a diploma or under-graduate degree, they will be considered to be children of the marriage. 6 Commencing January 15, 1988 Barry made payments in the amount of $125.00 in accordance with the Amended Order. ...

The Applicant was asked, but unable to provide any verification for the said deposit in the Updated Bank Statements. [31] As the Respondent submits, the Applicant bears the burden of showing that there are sufficiently serious shortcomings in the Decisions such that they cannot be said to exhibit the requisite degree of justification, transparency, and intelligibility: Aryan v Canada (Attorney General), 2022 FC 139 at para 16; Flock v Canada (Attorney General), 2022 FC 305 at para 15. [32] The Applicant’s primary argument is that the CRA agent should have considered the 2019 NOR, without any supporting documents such as invoices, as evidence that he met the minimum income requirement. ...

If, on the other hand, the assignment of the policy was valid, then the issue of whether the amount of $50,000 was properly included in the assessment under appeal can be stated briefly as follows, namely, that the assignment of the insurance policy by the Company to Mae Ritter Papp was a disposition of property by the Company to her, which is deemed by the Act to be a disposition by Gordon Papp to her, and that such disposition was an immediate gift inter vivos by Gordon Papp to his wife, and that its value was properly included in the assessment unless it could be shown that the disposition was made with consideration or that the property had no value and could not, therefore, be considered as an immediate gift inter vivos since it is obvious that there cannot be a gift of nothing. ...

The provisions of the Estate Tax Act that require to be considered are paragraph (a) of subsection (1) of Section 3, subsection (2) of Section 3, and paragraph (i) of subsection (1) of Section 58. ...

Foreign income tax was considered in C.J.R. v. Dowdall, O’Mahoney & Co., Ltd., [1952] 1 All E.R. 531, where a company resident in Eire carried on business at two branches in England. ...

And, whether farming should be considered as one of his sources of income for 1957 or not, the facts establish that his chief source of income for 1957 was his interest in the dance hall business. ...