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His Honour suggested that the words "the remainder, if any" could be interpreted to mean that if the taxpayer had no income, and his income could not then be considered income for the purposes of subsection 63(2). ...

Cordoba actually paid the $250 amount to reduce that balance to the $4,500 amount, and certainly the documents he introduced do not reflect any "contra-account" which would be sufficient to be considered payment of that debt. ...

In my view the proposition of the appellant that this should be considered a "loan" is not viable. ...

If, however, as in the Kamloops case (supra), a limitation period may be adjusted as to when it commences based on the facts, this must be considered. ...

At the hearing the appellant’s agent produced copies of 1977 and 1978 tax returns which the Minister’s counsel agreed to forward to Revenue Canada asking that they be considered in relation to the arbitrary assessments. ...

It is also recognized that this Court has no jurisdiction at the present time to deal with the 1983 assessment and hence the only matter to be considered is the merit of the 1981 appeal. ...

For the Minister, the situation was simple — the appellant corporation had not succeeded in showing that the Minister was incorrect in accepting as “prima facie” evidence that the August 4, postage meter date stamp, and August 8 receipt of documents stamp were the essential ingredients to be considered — notwithstanding Mr Duncan's firm belief that he had complied with the Act. ...

Subsection 167(5) adds certain criteria to be considered stating that no order should be made under subsection (1) unless inter alia the application was brought as soon as circumstances permitted it to be brought. ...

To whatever degree useful, these filings are to be considered an integral part of these reasons. ...

Fibromyalgia was formerly considered to be fibrositis, but recently it has been recognized as chronic pain that is not the result of inflammation. ...