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The Notice of Confirmation reads as follows: [translation] NOTICE OF CONFIRMATION BY THE MINISTER The objections you filed with respect to the income tax assessments issued for the 1995 and 1996 taxation years have been carefully considered, in accordance with subsection 165(3) of the Income Tax Act. ... In this respect, I feel that the Minister was justified in disallowing the excess expenses totalling $1,895.50, which the Appellant himself considered to be associated with the $8,000 research grant, even though he reported this amount as professional income. ...

Bourdages explained that the members were considered self-employed until the late 1980s. ... This caused problems for certain workers, who had considered themselves self-employed and had claimed deductions on their tax returns accordingly. [13]     Claude Fettaya, the president of Intervener Géo Tours Inc., testified that the Appellant did not return at least one of his calls offering him a tour. ...

By letter, Exhibit A-5, the Appellant was advised that pursuant to section 9.1 of the Employment Insurance Regulations 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. ... It is clear from the provisions of section 2 of the Insurable Earnings and Collection of Premiums Regulations, Part 1, that in order for an amount to be considered to be earnings for insurable employment the amounts have to be paid to the person by the person's employer in respect of that employment. ...

Paragraphs 45 and 46 of her reasons read: ARREARS: [45]       1999 Support-Related Amounts Payable- Having considered the evidence, I estimate that in 1999, Mr. ... It is paid to the appellant to enable her to cover her living expenses. [14]     The meaning of "allowance" was considered by the Supreme Court of Canada in Gagnon v. ...

In his view, the accused must prove six elements:   (1)        that an error of law or of mixed law and fact was made; (2)        that the person who committed the act considered the legal consequences of his or her actions; (3)        that the advice obtained came from an appropriate official; (4)        that the advice was reasonable; (5)        that the advice was erroneous; (6)        that the person relied on the advice in committing the act.   ... This aspect of the question must be considered from the perspective of a reasonable person in a situation similar to that of the accused. ...

All three sales are considered to be current to the effective date and no adjustment to their sale prices was required.   ... Sales 1 and 2 are considered to be inferior to the subject. The subject’s estimated value must therefore be above the highest price indicated by these two sales, in this case, above $120 per square foot. ...

According to the appellant, because he considered that he continued to operate the business as a motel, he felt that he was required to remit both taxes even though he did not charge the taxes on long-term rentals. ... At least two situations occur to me where a claim by a supplier might be considered: (a)         where a supplier does not collect GST from a recipient in respect of an exempt or zero-rated supply and then, erroneously, remits from its own funds an amount as GST to the government. ...

Stanfield be considered together.   a)       Stay Application   [13]     Respondent's counsel opposed the application to stay the appeals of the Other Appellants. ... Also, a section 163(2) penalty is of a personal nature, since knowledge or gross negligence is a key component of the penalty, and therefore each appellant's action or intention with respect to the facts leading to the individual's penalty must be considered separately ...

Dunbar's activities, however, be considered OSL's activities, such that it is OSL who is carrying on business outside Canadawith respect to the exploitation of petroleum? ... If, however, the business is providing services by way of subcontracting to a contractor, which services must necessarily be provided outside Canada, then the business can be considered to be carried on outside Canada. ...

Bergeron testified that he considered the following explanations by the appellant not very credible:             (i)      that the cash obtained from eight withdrawals [1] (in amounts varying between $350 and $1,050) totalling $5,400 had been used as partial payment for the "Harley" motorcycle acquired on August 18, 1998;             (ii)      that the cash obtained from two withdrawals, each in the amount of $3,000, [2] had been used as partial  payment for the snowmobile acquired on January 29, 1999; and             (iii)     that the cash obtained from eight withdrawals [3] (in amounts varying between $300 and $600) totalling $3,450 had been used as partial payment for the snowmobile acquired on December 14, 1999 ... Bergeron testified that he considered the following statements by the appellant not very credible: (i) that on November 4, 1999 he had received $5,000 cash from the sale of the snowmobile acquired in 1997; (ii) that he had used part of the proceeds of the sale ($450) for personal expenses; and (iii) that he had used the rest of the proceeds of the sale ($4,550) as partial payment of the purchase price ($8,000) of the snowmobile acquired on December 14, 1999 ...