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The amounts of income not reported were from an objective viewpoint substantial, especially if considered in terms of the income reported by the appellant for the three taxation years in question. [26] The explanations given by the appellant and his agent cannot explain, much less justify, such completely gross negligence. ... There is no need to refer to a list of precedents on the concept of gross negligence and extenuating circumstances that should be considered for the purposes of s. 163(2) of the Act when the evidence shows that a taxpayer deliberately failed to report money received that he or she knew to be taxable. ...

The losses sustained by such a taxpayer are considered to be personal or living expenses as defined in subsection 248(1) and not deductible. ... Some of the criteria to be considered are the extent of activity in relation to businesses of comparable nature and size, the amount of gross revenue from farming in relation to the relevant expenses, time spent in the operation as compared to other income earning activities, the profit and loss experience in the past years, the taxpayer’s training, the taxpayer’s intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...

Those portions of section 122.6 of the Income Tax Act respecting this question read, "eligible individual" in respect of a qualified dependant at any time means a person who at that time (a) resides with the qualified dependant, (b) is the parent of the qualified dependant who primarily fulfils the responsibility for the care and upbringing of the qualified dependant, (c) is resident in Canada, (d) is not described in paragraph 149(1)(a) or (b), and (e) is, or whose cohabiting spouse is, a Canadian citizen or a person who (i) is a permanent resident (within the meaning assigned by the Immigration Act), (ii) is a visitor in Canada or the holder of a permit in Canada (within the meanings assigned by the Immigration Act) who was resident in Canada throughout the 18-month period preceding that time, or (iii) was determined before that time by the Convention Refugee Determination Division of the Immigration and Refugee Board to be a Convention refugee, and, for the purposes of this definition, (f) where the qualified dependant resides with the dependant's female parent, the parent who primarily fulfils the responsibility for the care and upbringing of the qualified dependant is presumed to be the female parent, (g) the presumption referred to in paragraph (f) does not apply in circumstances set out in regulations made by the Governor in Council on the recommendation of the Minister of National Health and Welfare, and (h) factors to be considered in determining what constitutes care and upbringing may be set out in regulations made by the Governor in Council on the recommendation of the Minister of National Health and Welfare; "qualified dependant" at any time means a person who at that time (a) has not attained the age of 18 years, (b) is not a person in respect of whom an amount was deducted under paragraph (a) of the description of B in subsection 118(1) in computing the tax payable under this Part by the person's spouse for the base taxation year in relation to the month that includes that time, and (c) is not a person in respect of whom a special allowance under the Children's Special Allowances Act is payable for the month that includes that time. [6] Regulation 6302 is applicable after 1992. ... For the purposes of paragraph (h) of the definition of 'eligible individual' in section 122.6 of the Act, the following factors are to be considered in determining what constitutes care and upbringing of a qualified dependant: (a) the supervision of the daily activities and needs of the qualified dependant; (b) the maintenance of a secure environment in which the qualified dependant resides; (c) the arrangement of, and transportation to, medical care at regular intervals and as required for the qualified dependant; (d) the arrangement of, participation in, and transportation to, educational, recreational, athletic or similar activities in respect of the qualified dependant; (e) the attendance to the needs of the qualified dependant when the qualified dependant is ill or otherwise in need of the attendance of another person; (f) the attendance to the hygenic needs of the qualified dependant on a regular basis; (g) the provision, generally, of guidance and companionship to the qualified dependant; and (h) the existence of a court order in respect of the qualified dependant that is valid in the jurisdiction in which the qualified dependant resides. [7] Reviewing the facts, the Court finds that both parents were equal in respect to (a) and (b). ...

R. [1] which considered Regulation   16(1)(b) and specifically the definition of “establishment in Canada” and the meaning of the words “paid at or from” the employer’s Canadian establishment ... Canada (The Minister of National Revenue), [2] the Court considered the meaning of the term of placement agency in the CPP Regulations. ...

Sheridan____________________________________________________________________   ORDER   Whereas the Appellant, Charlene Echum, applied to have the dismissal of her Informal Procedure appeals of her 2004, 2005, 2006 and 2007 taxation years set aside under section 18.21 of the Tax Court of Canada Act;             And having considered the factors set out in the Appellant’s letter in light of the criteria for the setting aside of an order of dismissal under paragraphs 18.21(3)(a) and (b) of the Act;             And not being satisfied that the Appellant has shown that “it would have been unreasonable in all the circumstances” for her to have attended the hearing;   IT IS HEREBY ORDERED THAT the Appellant’s application to set aside the Order dated September 15, 2011 is dismissed in accordance with the attached Reasons for Order.   ... During that time, no one appeared for the Appellant nor was any call received to explain the Appellant’s absence. [12]          It is against this backdrop that the Appellant’s failure to appear at the September 12, 2011 hearing must be considered. ...

It considered the fees to be exempt under Schedule V, Part III, Section 8 of the Excise Tax Act, which reads, in English: A supply, other than a zero-rated supply, made by a government, a school authority, a vocational school, a public college or a university of a service of instructing individuals in, or administering examinations in respect of, courses leading to certificates, diplomas, licences or similar documents, or classes or ratings in respect of licences, that attest to the competence of individuals to practise or perform a trade or vocation except where the supplier has made an election under this section in prescribed form containing prescribed information. ... Nonetheless, those occupations are considered to be trades or vocations in the language of the modern world. [15]     In the Court's view the same may be said for an entrepreneur. ...

If allowing costs for research is considered, there must be some account of the amount of time allocated to the specific research in order to determine whether it is reasonable and whether it is necessary. ... The above amount of $969.51 has been reviewed and considered in relation to the The Queen v. ...

She considered that the house was between 75 per cent and 80 per cent completed at the time the couple moved into it. ... Indeed, although the appellant considered the house habitable for her very specific purposes-given the urgency of moving into the house even though not everything was completed-on the basis of the evidence, it is reasonable to conclude that construction of the residential complex was not substantially completed by August 1998, and was probably not until late fall 1998. ...

He stated that he could not understand the present assessments because all he had done was to put his own money into his business without ever turning a profit. [8]      The main issue in this case is the amount of rent representing approximately $6,000 each year that was considered a benefit to the appellant and was included in his personal expenses. ... All things considered, this point remained rather unclear, as did the nature of the amount received from Alimentation Doyon et fils Inc. in 1996. [15]     From 1996 to 1998, based on the appellant's net worth, he had bank balances of $6,261, $6,785 and $4,827 respectively but also had bank loans of $11,740, $7,780 and $7,542 respectively. [16]     The appellant company's balance sheet as at December 31, 1998, showed an accumulated deficit of $101,993. [17]     Arthur Doyon was paid no wages. ...

What must be considered is why did the business incur the expenditure. ... The Queen, Cullen, J. considered the requirements of section 230 and stated as follows: Section 230 of the Act requires taxpayers to keep adequate books and records. ...