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  [4]                Having considered these memoranda, we are of the opinion that intervention in the trial judgment is unwarranted ...

No. 1376 (A.O.) 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. ...

SHARLOW J.A. [1]                 Having carefully considered the submissions of counsel and the reasons for the decision of the Tax Court Judge, we are all of the view that the Tax Court Judge erred in law in reaching his conclusion. ...

In our opinion the Judge considered all the evidence before him and, having reviewed it, decided that the applicant had not discharged the onus of proving on the balance of probabilities that she was employed as she alleged. ...

The other items are all awarded, as they were considered reasonable; accordingly, the fees total $1,375 ...

Employment in any of the following employments, unless it is excluded from insurable employment by any provision of the Regulations, is included in the insurable employment: (g) employment of a person who is placed in that employment by a placement or employment agency to preform services for and under the direction and control of a client of the agency, where that person is renumerated by the agency for the performance of those services. [2]         In particular the evidence, when considered in light of the assumptions relied upon by the Minister, allowed the Tax Court Judge to conclude that the lumpers were placed in employment under the supervision of the shippers and were paid by the Applicant for the service which they provided. [3]         The Application will be dismissed with cost.         ...

The Tax Court considered the appellant’s arguments raised with respect to how he structured his affairs and with respect to whether the income was earned by him personally or by one or more of his various corporate entities. ...

This is the first factor which must be considered in disposing of a motion such as this. [3]                In the present case, the proposed appellant does not have an arguable case as the record shows that the notices of appeal before the Tax Court were not filed before some five years had expired after the notices of confirmation were issued. ...

Like him, and for the same reasons, we fail to see how the claimed deduction can be considered to have been incurred to gain or produce an income for the purposes of paragraphs 18(1)(a) and (b) of the Income Tax Act. [4]                The appeal will be dismissed with costs. ...

To obtain a credit it is necessary that a gift be made to a qualified charity and that the gift be proven by filing with the Minister a receipt that contains prescribed information. [4]                The Judge then considered the evidence before him and made two findings. [5]                First, the Judge doubted the truthfulness of the appellant’s claim that she donated $10,250.00. ...