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If it had been, more serious penalties under subsection 163(2) might have been considered. ...

Conclusion [5]      I am satisfied that there is no rational basis for the Appellants' proposition that because the "mortgage loan" was obtained for two different purposes, it may be considered by the borrowers for tax purposes as two separate loans. ...

  [9]      The problem lies not with that fact but, essentially, with the applicable legislative provision that periodic payments must be made under a written agreement or order by a competent tribunal in order to be considered support payments ...

Thus the reduction of $67.87 to this amount results in an employment expense allowed to the Appellant of $3,341.34 in 1993. [6]      For 1994 counsel for the Respondent reduced the $567.58 figure in respect of advertising and promotions to $250 representing one-half of what the Minister considered a reasonable amount of $500. ...

Canada, [1998] 1 F.C. 124, the question as to whether the director has met the standard of care is a question of fact to be resolved in light of the personal knowledge and experience of the director. [17]     The personal knowledge and experience of the appellant must therefore be considered. ...

I have carefully considered the testimony of the Appellant and I accept her testimony. [14]     However, I agree with the decision of the Minister regarding the unproven statement that Wen Ling Zhu was given the sum of $19,800.00 by her parents in 1996. [15]     The Appellants' appeals will be allowed and the Minister is instructed to issue Notices of Reassessment on the following basis: Wen Ling Zhu 1997 1998 Understated Net Income $20,644 $9,286 Deduct $10,000 re gift from parents of son-in law [1] $10,000 Deduct $2,150 re sale of inventory $2,150 Understated net income $10,644 $7,136 Xiao-Pei Huang 1997 1998 Understated Net Income $20,644 $9,286 Deduct $10,000 re gift from parents of son-in law [2] $10,000 Deduct $2,150 re sale of inventory $2,150 Understated net income $10,644 $7,136 [16]     In reviewing the documents that were filed as exhibits with the Court, I could not reconcile the recommendations contained in the Report on the Notice of Objection (See Exhibit R-2). ...

In his opinion, there is no specific provision in the Act that authorizes the deduction of legal expenses either for the support payer or for the support recipient. [8]      In Sabour, supra, Judge Bowie of this Court wrote as follows regarding the position taken by Judge Archambault in Bergeron: [10]     As Archambault J. has said, the line of reasoning that he developed in Bergeron was not specifically considered in any of the decided cases. ...

Hatton considered while reaching her conclusions. It is crucial to the litigation that the Appellants be able to determine why their appeals were denied and to discover if they were granted fair and comprehensive consideration after their initial objection to the assessments. ...

Haines had listened to the Appellant's evidence (which he agreed with) and confirmed that in his professional dealings with the Appellant, he considered the Appellant blind most of the time because of his restriction. ...

She received cheques from the hospital for approximately the full amount of her normal wages that included the 75% from the W.C.B. and the 25% top up amount pursuant to the collective agreement as if she had been at work; she was not considered by the hospital to be on sick leave but was paid as if she was on continuous service. [21]     During the periods in issue, the worker received his full salary and health and dental insurance benefits as though his employment with the employer had not been interrupted. [22]     The worker received his full remuneration from the appellant in accordance with the Collective Agreement, and the CSST reimbursed the appellant for a portion of that remuneration paid to the worker. [23]     Whether the total amount received is called an income replacement indemnity or wage-loss insurance is of little importance. ...