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.), at p. 111: One feature which seems to run through the instances is that, under a contract of service, a man is employed as part of the business, and his work is done as an integral part of the business; whereas, under a contract for services, his work, although done for the business, is not integrated into it but is only accessory to it. [6]      Considered in light of the Sagaz factors, the evidence does not support the conclusion urged by the Appellant that he was an independent contractor; for the reasons set out below, I am satisfied that he performed his general manager duties as an employee. ...

Greene also relied on the SRED application as evidence that the Appellants themselves considered themselves to be not dealing at arm's length, yet that application is equally consistent with them simply being specified shareholders as it is with being at arm's length. [11]     Mr. ...

I have carefully considered the Appellant's testimony and I accept the testimony of the Appellant that she had business meetings with her clients at the various restaurants referred to by her in evidence.   ...

The Minister considered further that the Appellant's mother, Kima, had zero income although no return was filed for her and thus the paragraph 118(1)(d) deduction by the Appellant was allowed only for her mother. [7]      The Appellant filed a letter of Yorkdated November 16, 2005, it reads as follows: To Whom It May Concern: November 16, 2005 RE: Issaak Rokhline Tax Form T5007 for Year 2003 The family of Issaak Rokhline and Kima Oulman was on our social assistance program in the year 2003. ...

The judge should have considered the Wiebe Door factors in the light of this uncontradicted evidence and asked himself whether, on balance, the facts were consistent with the conclusion that the dancers were self-employed, as the parties understood to be the case, or were more consistent with the conclusion that the dancers were employees. ...

Sagaz Industries Canada Ltd. [3] The significance of each test must be considered in the overall context that the entire facts of the case require. ...

One might imagine that work under the auspices of NATO could be considered similar to work under the auspices of the United Nations, yet it is not my role, to make a legislative change. ...

., [1995] 2 C.T.C. 2454, Justice Rip of the Tax Court considered the word "throughout" in relation to time periods, and at paragraph 10 noted:    Mr. ...

  [12] As far as the notice contemplated by section 122.62(4) is concerned, the Minister of National Revenue did have notice of several facts and, had he considered them, he probably would have concluded that Mrs. ...

(d)     for greater certainty, no other activity, including working, housekeeping or a social or recreational activity, shall be considered as a basic activity of daily living. [6]      Lamarre Proulx J.'s decision in Biron v. ...