Search - considered

Batshaw considered Mr. Gagnon to be an experienced businessman versed in at least some tax matters. [4]      Mr. ...

CHANCE OF PROFIT AND RISK OF LOSS [11]     Under this criteria, the evidence is rather sparse and could be considered neutral insofar as it is relied upon by either the Minister or the Appellant. ...

No. 316, the Minister's presumptions should be considered accepted unless they have been specifically refuted by the Appellant. [17]     It is important to note that in the present case, it was proven that the Appellant did not receive any wages for the services rendered to the Payer. ...

Analysis [5]      In my opinion the evidence does not contradict the statements and assumptions in the Amended Reply quoted above. [6]      The Appellant states that notwithstanding the abduction of Nicholas and Alexandra, who are twins, they still should be considered as qualifying as residing with the Appellant. ...

A similar argument was considered by the Federal Court of Appeal in the Minuteman Press [3]   case. ...

  [8]      The parties relied on the following provisions from the regulations:     Employment Insurance Regulations   9.1       Where a person's earnings are paid on an hourly basis, the person is considered to have worked in insurable employment for the number of hours that the person actually worked and for which the person was remunerated   9.2       Subject to section 10, where a person's earnings or a portion of a person's earnings for a period of insurable employment remains unpaid for the reasons described in subsection 2(2) of the Insurable Earnings and Collection of Premiums Regulations, the person is deemed to have worked in insurable employment for the number of hours that the person actually worked in the period, whether or not the person was remunerated.   ...

Dussault during the 2001 taxation year was not deductible as a support amount or other allowance payable on a periodic basis as it arose from a judgment handed down after April 30, 1997, and the aforementioned amount is considered a child support amount pursuant to subsection 56.1(4) and paragraph 60(b) of the Act.   ...

The specific question of frequency and duration which is asked in the act is difficult because these are considered ongoing interventions and thus I cannot quantify them in a simple fashion as one could for dialysis treatments, for example. ...

Office use of home expenses are deductible if (1) this office was his principal workplace or, (2) it was used exclusively for the purpose of earning income from the business and used on a regular and continuous basis for meeting clients or patients in respect of the business. [6]      In my opinion, the Appellant's home office cannot be considered his principal workplace either from the point of view of the amount of time he spent there, or from the point of view of the quantity of work conducted there. ...

The document was received by the Minister on January 4, 2001. [6]      The assessment was made on the basis that: (a)       The Appellant exported the vehicle when he drove it into Montana on April 20, 1999, (b)      The Appellant's application for the rebate was filed after the expiry of the one-year limitation period laid down by s. 232.2(a) of the Act. [7]      The meaning of the word export was considered by the Supreme Court of Canada in Carling Export Brewing and Malting Co., [1930] S.C.R. 361 and the following was adopted:... ...