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Having been entered into in April 2000, it speaks of the $5,000 per month as a future obligation and confirms that the $5,000 monthly payments from January to March, 2000 are to be considered to have been paid pursuant to the April 2000 agreement. ... Rather, it says that these sums, already paid, are to be considered as paid under the 2006 agreement. ...

I trust that the following factors will be considered when determining whether the Court will cancel or waive the penalty:   (a)        I have a 40+ years of history of compliance with my tax obligations; (b)        I have never knowingly allowed a balance to exist upon which arrears interest has accrued; (c)        I have exercised a reasonable amount of care and have not been negligent or careless in conducting my affairs under the self-assessment system until this event and; (d)        I acted quickly to remedy any delay or omission as I did pay the full amount of this reassessment prior to the due date of March 16th, 2006.   ...   [11]      In drawing the line between "ordinary" negligence or neglect and "gross" negligence a number of factors have to be considered. ...

  [17]          It was t he Respondent’s shifting position on the Religions Assumptions from relevant to unimportant and back to decisive, especially when considered in light of the fact that they were ultimately irrelevant, together with their relevance having been strongly questioned by the Court in the motion to strike, that unnecessarily lengthened the proceedings. ... The presence and contribution of both of the taxpayer’s counsel are being considered in my fixing of costs in this matter.   ...

He did not say whether or not, in 2000, he considered D&M a "new" franchise ... Tucker had considered paying CCRA the $40,000 directly but Mr. Dibblee said he "needed room to manoeuvre". ...

During the period in issue, it is not clear whether the Payor considered the Worker as a self-employed worker or as an employee.  The Worker considered himself an employee.   Pursuant to the Code, a contract of employment must meet the following three criteria:   (1)    Performance of work:   There is no doubt that the Worker provided towing services for the Payor.  ...

(c)           Those people were either regular employees (office and construction workers) or sales agents, including the Worker, whom the Appellant considered self-employed. ... The Appellant's conduct clearly shows that the Workers were considered self‑employed: T4A slips were issued, there were no source deductions, there were no fringe benefits, there was no vacation pay, etc. ...

Gainer’s letter of September 21, 2005, she states “In order for amounts to be considered support amounts one of the requirements is that the $1000.00 payments received by Ms. ... Her rights were vested and she cannot be considered as paying herself. ...

In Stewart, the Supreme Court highlights some of the criteria, indicia of commerciality and badges of trade that should be considered. ...   [35]          Again, this does not even approach being able to be considered to be a business. ...

Initially, she received a fixed sum of money on account of her commission, which the Payor considered an advance. ... In addition to being individual indicia of subordination, the following facts, considered together, constitute an indicia of subordination that I would characterize as an indicia of integration into the business:                            (i)                The Appellant worked only for the Payor during the relevant period.                          ...

In dismissing the appeal, Rowe, J. considered Wilson but distinguished that decision saying in that case, “there is a capacity to follow through on an alternative method of allocation due to the different zoning uses of the land and the de facto segregation inherent in the Property with the commercially zoned portion fronting on a major highway” [19] ... I do not think it is reasonable, where one asset is purchased such as the farm here, and it has both personal and business aspects, to allocate the entire interest expense to the business aspect of the Property. [20]   [16]     Bowman, J. also considered Wilson but distinguished it on the basis that in that case there was “persuasive evidence” [21] before the Court to justify not allocating the borrowing costs between personal and business use ...