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I point out that the auditor Careen in his testimony, detailed the various factors which he considered before recommending the imposition of penalty and in addition to those mentioned above, specifically considered the fact that the Appellant is a businessman who has successfully operated a stationery store and a courier service through a corporation since 1988. [19]          In dealing with the imposition of penalties, Strayer J. in Lucien Venne v. ...

Rankin, and the changes in American tax law had a negative and unexpected impact on the business, no evidence was presented to show what profit the taxpayer might have earned had these events not occurred and whether the amount would have been considered substantial when compared to his professional income. ... It is clear that this is not so and it is the net farm income that has to be considered. ...

Pierre-Louis told her that she was interested in signing a contract under which she would be considered a self-employed worker. She did not want employment that was considered to be insurable within the meaning of the Act. ...

It was considered by the Chief Judge- and I think I said this on Tuesday in Dr. ... At that time he asked me to recuse myself, and he asked for an adjournment of his appeal even if I chose not to recuse myself, on the basis that he was no longer being given 30 days' notice of the hearing of his appeals as the Rules provide for, in as much as it was less than 30 days prior to July 10 when he was told that we would begin on July 10. [5]            I considered his motions during the two-hour interval between the two 40-minute sessions that were held on Tuesday, and after careful consideration of my Reasons for Judgment, given about four years ago, and the passage in particular to which Dr. ...

The tax advantage which is received from gifts is not normally considered a " benefit " within this definition, for to do so would render the charitable donations deductions unavailable to many donors. ... I agree with counsel for the respondent that it is much more likely, given the evidence, that the appellant stopped claiming charitable gifts in 1994 because that was the year the Order, which was being investigated, ceased issuing false receipts for an amount much higher than the actual amount of the gift. [37]     The fact that the appellant's income increased significantly in the following years along with the fact that he never again made any substantial gifts, when considered in light of the respondent's extensive evidence demonstrating the existence of the fraudulent scheme devised by the Order and specifically by fathers Joseph El-Kamar and Claude Nadras, with whom the appellant dealt regularly, casts serious doubt on the appellant's philanthropic side. [38]     More than likely, the appellant was seeking only to benefit personally through the alleged gifts to the Order. ...

Justice Ross Goodwin of the Superior Court rendered judgment on the motion to cancel arrears and support brought by the appellant against his former spouse; (d)            by the said judgment, that court confirmed and gave effect to paragraphs 2 and 4 of the agreement signed on August 18, 1998, and formally recognized the parties' understanding set out in paragraphs 1, 3 and 5-9 of that agreement; (e)            in paragraph 2 of the agreement, the appellant's former spouse waived all support arrears owing to her by the appellant on August 18, 1998; (f)             according to paragraph 3 of the agreement, all the other clauses of the agreement confirmed by the divorce judgment continued to apply, the parties being of the view that paragraph 9 applied from then on, which meant that support was set at $385 payable every two weeks; (g)            each party was held to be responsible for paying his or her own legal expenses; (h)            to back up his claimed deduction for support payments, the appellant submitted the following supporting documents: ·          a list of cheques for the support payable to his former spouse during the 1998 taxation year; ·          photocopies of cheques payable to his former spouse, which are practically illegible; ·          a photocopy of his bankbook, some of the entries in which are also illegible; (i)             the Minister was able to identify eight payments of $385 each and therefore allowed a total of $3,080 as a deduction for support payments; (j)             during the year at issue, the appellant paid $3,125.43 to the law firm of Garneau, Verdon, Michaud of Québec for professional fees and disbursements in connection with proceedings to have support and arrears cancelled; (k)            the $3,125.43 in legal expenses incurred by the appellant for the 1998 taxation year were not so incurred for the purpose of gaining or producing income from a property or business but are considered personal or living expenses. [4]            The appellant had initially been ordered to make support payments to his former spouse by a judgment rendered by the Honourable Mr. ... He went on as follows: 46             Not only is support not income from property within the usual meaning of that term, but it also cannot be considered as such given the overall context in which the term income from property is used in the Act. ...

His plan was accepted. [10]     Upon acceptance, the file was automatically referred to a specific department and it was all processed in accordance with the collective agreement based on a very detailed table. [11]     After his plan was considered and accepted, the appellant was informed by letter that he was entitled to an amount of $14,222 (Exhibit A-4). ... There is nothing in the relevant Articles of the Agreement to suggest that either the employer or the employee considered a sabbatical salary to be a grant or fellowship or any other form of remuneration.                                                                         ...

It was considered to have been successful and in or about 1991, the Anishnaabe Affairs Committee was formed. ... Third, the training equipped them for employment in the commercial mainstream in any licensed childcare setting in Ontario and was not limited to reserves. [17]          A similar proposition was considered by Archambault J. in Desnomie v. ...

Thomassen saw and one half of the rear external wall on the main floor and over one half of the external walls on the second floor were new when the Appellant was finished. [7]            The definition of "substantial renovation" in subsection 123(1) of the Excise Tax Act reads: “substantial renovation” of a residential complex means the renovation or alteration of a building to such an extent that all or substantially all of the building that existed immediately before the renovation or alteration was begun, other than the foundation, external walls, interior supporting walls, floors, roof and staircases, has been removed or replaced where, after completion of the renovation or alteration, the building is, or forms part of, a residential complex; Thus the new additions, the new roof and the redone or new exterior walls and the new support beams are not to be considered. ... But substantial means that "essentially" or "really" all of the residential complex that is to be considered was replaced. ...

Ltd. is not considered as "insurer" for GST purposes, or acting as an agent for the insurance company, the supply is deemed taxable at 7%.                 4.              ... Under this arrangement, these costs were properly considered expenses incurred by the Appellant in making the brokerage service, and so the reimbursement of them came within the purview of section 178. ...