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Having reviewed the record and Justice Hogan’s careful and thorough reasons, and having considered the written and oral submissions of A&T Tire & Wheel Ltd., we are unable to detect any such error ...

Justice Webb concluded that the absence of those particulars was not a fatal omission in this case because the intention of the appellant who signed the form was clear from the surrounding circumstances (2011 TCC 493). [2]    Having considered the written and oral submissions of the appellant, we have not been persuaded that Justice Webb erred in law in deciding as he did. ...

However, having carefully considered the record and the parties’ submissions, both written and oral, we are not persuaded that the Judge committed any reversible error with respect to the law, or any palpable and overriding error in applying the law to the facts or in making findings of fact ...

Having reviewed the record and considered the submissions of counsel for the appellant, we cannot accept this argument. ...

  [2]                As for the penalty, the Court has considered whether the appellant Gilles Bélanger could have been justified in believing that the Minister of Revenue had recognized Lac Genest as being his residence for the taxation year preceding the years at issue ...

  [2]                In concluding as he did, Justice Favreau considered all the evidence, including the appellant’s testimony, and made findings of fact and law. ...

  [2]                In our view, in order to succeed on his argument that the child tax credit under United States tax legislation should not have been considered in the determination of the tax paid in the United States, the appellant was required to adduce expert evidence with respect to United States tax legislation and more particularly with respect to the child tax credit under that legislation ...

.), that the same point in the ranges throughout the tariff need not be used, as each item for the services of counsel is discrete and must be considered in its own circumstances. ...

Appellant                                                                                                                                                                                                                                        and THE MINISTER OF NATIONAL REVENUE Respondent REASONS FOR JUDGMENT OF THE COURT (Delivered from the Bench at Toronto, Ontario, on January 18, 2005) ROTHSTEIN J.A. [1]                In this employment versus independent contractor appeal from the Tax Court, a significant issue is whether the individuals were carrying on business on their own account when the matter was considered from their perspective. ...

BETWEEN:                                                      REDEEMER FOUNDATION                                                                                                                                         Respondent                                                                                                                                                                                                                                        and THE MINISTER OF NATIONAL REVENUE Appellant REASONS FOR JUDGMENT OF THE COURT (Delivered from the Bench at Toronto, Ontario, on June 15, 2005) EVANS J.A. [1]                This is an appeal by the Minister of National Revenue from an order of Rouleau J. of the Federal Court, dated April 11, 2005, permitting Redeemer Foundation to file a notice of application for judicial review, even though more than 30 days had elapsed since the decision sought to be challenged was made. [2]                Having heard full and able arguments advanced on behalf of the parties, and having considered the criteria relevant to the exercise of discretion for the grant of an extension of time to file an application for judicial review, we are not persuaded that the Motions Judge made any reversible error when he dismissed the appellant's motion for an adjournment and, in the exercise of his discretion, granted the respondent's motion for an extension of time for filing its notice of application for judicial review. [3]                For these reasons, the appeal will be dismissed with costs fixed in the lump sum of $3,400.00 inclusive of disbursements and GST.                                                                                                                                    ...