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However, in one situation a tutor by the name of Pamela Merritt was initially considered by the CRA to be an employee of Sunrise. ...   [35]     I have also considered the following Tax Court decisions:   1.                  ...

The appellant and his wife considered this proposal and decided to accede to it. ...   [17]     Family relationships have been considered in a number of cases in this court dealing with the liability of directors under the Income Tax Act and the Excise Tax Act, but in the final analysis, the extent to which a director is justified in relying upon an employee of the company, relative or not, is a question of fact that must be decided in the particular circumstances of each case. ...

  [34]     In addition to this, when the evidence regarding the use of vehicles is considered as a whole, the amount of business use that is claimed, 17,000 kilometers, seems very high ... In addition, a deduction for maintenance and repairs on the truck in the amount of $1,032.30 should be allowed;   (b)        with respect to general business expenses, a total of $1,077 should be allowed as current expenses and $2,810 should be considered as the cost of capital expenditures on equipment;   (c)        with respect to meals and entertainment, a deduction should be allowed in the amount of $471.49;   (d)        with respect to a cell phone, a deduction in the amount of $400 should be allowed; and   (e)         with respect to parking, a deduction in the amount of $11.70 should be allowed ...

(denied)     [5]               In addition, the Minister relied on the following factors, set out in paragraph 6 of the Reply to the Notice of Appeal, in imposing on Gilles Bélanger the penalty under subsection 163(2) of the Act in respect of the $26,440 added to his 2004 employment income and the $5,335 added to his 2005 employment income:   [TRANSLATION]   (a)        Based on the conclusion that the Minister drew from the facts set out in paragraph 5 above, the Appellant falsely used the address of the building in Baie-Trinité so that he could be considered eligible to receive tax-free allowances ... (admitted)   [7]               In addition, the Minister relied on the following factors, set out in paragraph 6 of the Reply to the Notice of Appeal, in imposing on François Bélanger the penalty contemplated in subsection 163(2) of the Act in respect of the $24,078 added to his employment income for the 2004 taxation year:              [TRANSLATION]   (a)        Based on the conclusion that the Minister drew from the facts set out in paragraph 5 above, the Appellant falsely used the address of the building in Baie-Trinité so that he could be considered eligible to receive tax-free allowances ...

Plitt cannot reasonably be considered to possess confidential information in these circumstances ... In one prior decision, this was not considered to be a significant factor in determining disqualification. ...

The problem has often been considered in actions brought under s. 4(1)(e)(i) of the Divorce Act and, generally speaking, a finding that the parties were living separate and apart from each other has been made where the following circumstances were present:   (i)      Spouses occupying separate bedrooms. ... Reference to these seven factors will prevent an inappropriate emphasis on one factor to the exclusion of others and ensure that all relevant factors are considered.  ...   ...

The audit also revealed that an amount of $1,707.80 was erroneously considered as a GST return in relation to the manager contract adjusted. ... The use of that space for household purposes as well as the need for that space to provide a minimal degree of comfort for the occupants of that residence must also be considered.   ...

Canada, [2009] 1 S.C.R. 3 (“ Lipson ”) as confirming that the direct and immediate use of borrowed money is the only factor to be considered in ascertaining the purpose of the loan ... In light of Singleton, it would be difficult to suggest that this series of transactions would be considered artificial or lacking commercial reality in some fatal way. ...

There are many cases in which the matter has been considered both in this court and the Federal Court of Appeal. ... Where senior and experienced counsel advances a proposition of fact or law in a pleading that merits serious consideration by a trial judge, it is at least presumptuous and at most insulting and offensive to force counsel to face the argument that the position is so lacking in merit that it does not even deserve to be considered by a trial judge. ...

Unlike the earlier Companies Act, R.S.B.C. 1924, c. 38, that was considered in British Columbia v. ... There are no facts before me as to whether the Minister considered that there was additional tax owing by the company beyond that already assessed. ...