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The denial of the ITC implies that the Ferrari is not considered to be inventory on hand as at January 1, 1991 but capital property. ...

Settlement offers should be taken and considered seriously as costs may be awarded in an amount significantly in excess of tariff against an unsuccessful party who has not accepted a settlement offer that would have been more favourable than the outcome at trial. ...

  [6]               Since the return was made outside the normal reassessment period, t he Minister considered that the return was a request by Mr. ...

DECISION:   [8]     In addition to the oral submissions of the parties, I have also considered the letter from the Appellants dated April 16, 2012. ...

The C4, C5 and C6 discs in Trina's neck had been broken and she was considered to be a quadriplegic. ...

., [2001] 2 C.T.C. 2048, Tardif J. considered a corporate appellant's inability to pay a lawyer's fees as "a decisive factor" in such a motion as this. [8]            In this case the appellant's financial statements for 1997 and 1998 were put in evidence and they show a company in very healthy financial condition. ...

In interpreting the Agreement, I have considered the sworn testimony of Mr. ...

Loan Year                        Amount Repayments           Amount Owing 1992                                  $28,166.34                  $10,735.17                  $17,431.17 1993                                   $ 8,678.14                  $15,120.51                  < $6,442.37 > 1994                                  $24,465.03                  $14,882.15                   $ 9,582.88 1995                                  $38,806.80                  $25,592.68                  $13,214.12 1996                                  $11,800.00                  $18,256.11                  < $6,456.11 > 1997                                  $40,359.60                   $ 6,445.86                  $33,913.74 1998*                               $11,310.98                  $34,337.51               < $23,026.53 > Balance                                                                                                  $38,216.90 *to August 5 th, 1998 [12]          I have carefully considered the testimony of the Appellant, the testimony of Dennis, the testimony of Mr. ...

ANALYSIS [11]          I have considered the testimony of the Appellant and I have concluded that in the 1997 and 1998 taxation years he was operating a business under the name of "Timo Enterprises". ...

It was the Appellant’s position that the business use of the vehicle was greater than 90%. [13]          In reaching the conclusion that the Appellant’s business use of his vehicle was 75%, the appeals officer considered that the Appellant had one vehicle and he used this vehicle to drive to and from his office. [14]          The onus was on the Appellant to show that the business use of his vehicle was greater that 75%. ...