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While displayers once engaged could select someone else to complete the employment, the area manager was usually involved in the change and the replacement would have to be a person who was considered suitable. [12] During the period in question, the Appellant engaged the Worker to display such products in several retail settings. [13] The area manager in question negotiated an hourly rate, the Worker performed basically the services hereinabove described, submitted her invoices and was paid by cheque. ... The most that can be said is that control will no doubt always have to be considered, although it can no longer be regarded as the sole determining factor; and that factors, which may be of importance, are such matters as whether the man performing the services provides his own equipment, whether he hires his own helpers, what degree of financial risk be taken, what degree of responsibility for investment and management he has, and whether and how far he has an opportunity of profiting from sound management in the performance of his task. ...

[8]            The witnesses were unanimous that it was considered desirable for as many producers and buyers as possible to be covered by the Hartford insurance. No action was required on the part of producers or buyers to trigger coverage; all animals were considered to be covered, and the premiums were invoiced to the producers and to the buyers, unless they took positive steps to opt out of the coverage. ...

Wannan operate to discharge the liability of the Appellant. [2]            It should be noted that the Notice of Appeal raised the issue of whether contributions to a Spousal RRSP can be considered as transfers under section 160 of the Act and also raised the issue that the value of the contribution should be reduced by any tax payable by the Appellant to collapse the Spousal RRSP. ... WHEN THE APPELLANT'S LIABILITY ARISES [20]          The Appellant argues her spouse did not know about the Minister's assessment in respect of the 1988 and 1989 taxation years until 1993, and consequently contributions prior to this date should not be considered in calculating the Appellant's joint and several liability. ...

The appellant mistakenly omitted to calculate the time spent by the tenant in his room and in the bathroom, each of which he considered to have been used 100 per cent by the tenant. [8]            The auditor from the Canada Customs and Revenue Agency ("CCRA") used another method (Exhibit R-3). ... (c) Integral Part or Separate Asset- Another point that may have to be considered is whether the expenditure is to repair a part of a property or whether it is to acquire a property that is itself a separate asset. ...

In my view, it is only as of April 1, 1996, when the account changed holders and was put in the name of Farm of the Mountain, that it can be said to have belonged to the appellant. [29]          Third, contrary to what counsel for the respondent claim, evidence was in fact adduced that account 1916 was used, regardless of the period being considered (that is to say, in the period from 1994 to March 31, 1996, and subsequently in the period from April 1, 1996, to March 31, 1997), to pay both the expenses relating to the farm operation and those that may be characterized as living expenses of the Coulson-Laframboise household. ... Where a joint bank account is used for a number of purposes or to pay a number of types of expenses, the problem is to identify correctly the expenses that may be considered as "expenses of the marriage". ...

I have previously considered this question in Slobodrian v. Canada, [1998] T.C.J. ... Gebrayel, it may be believed that they considered that the total amounts of those receipts had actually been earned by their volunteer work. ...

Penny did not give a precise estimate but also did indicate that a considerable amount of time was spent in the farming operation. [10]     The Appellants separated in 1998 and in the family division of property Calvin received the farm and Penny received other assets. [11]     The custom work performed in 1997 brought in income of $22,470 which the Appellants considered as farming income and filed on a fifty-fifty basis for that amount as well as the other farming income and expenses. ... Moreover the farming activities were expanding over the years from 1996 to 1999. [19]     For all of these reasons, the appeals are allowed with one set of costs and the matters are referred back to the Minister of National Revenue for reconsideration and reassessment on the basis that for the years 1996 and 1997 the Appellants were entitled to their full farming losses as claimed and that for those years the custom work revenues are to be considered as part of and included in the farming revenues. ...

  [17]    The appellant therefore claimed an ABIL since he considered that he held a capital claim against the corporation, a claim which had become a bad debt in 1992 ... He therefore considered that he had a claim against the corporation. The word "claim" not defined in the Act, the appellant referred to the definition in the dictionary, Le Nouveau Petit Robert, Paris, Dictionnaires Le Robert, 2000, which reads as follows: [TRANSLATION] " 3.   ...

The collection of GST was never an issue considered since all of its products were to be sold in the US. ... In this context, it should be noted that the Appellant claimed ITCs totalling $18,655 of which $9,283.84, almost 50%, was disallowed by the Minister. [8] No acceptable explanation for the misrepresentations has been presented to the Court. [13]          The Appellant also contends that its claim for ITCs in the amount $2,186.59 relating to expenditures incurred before its date of registration should not be considered a misrepresentation because the Appellant did not understand how section 171 of the Act worked but did not misrepresent the facts when "while putting in an accurate figure of the GST that he had paid, didn't realize and understand that in law some of that was ineligible". [14]          It cannot be disputed that the language of section 171 of the Act is convoluted and difficult. ...

However, there is a basic principle to be considered with respect to expenses such as these. ... If it does, an adjournment is granted to permit the Appellant to comply with the Rules. [17]          I have considered the issue raised on behalf of the Appellant and find nothing whatsoever of any legal merit therein. ...