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  [13]     With respect to the loans and repayments, I am not satisfied on the evidence that repayments were required to be considered as part of the net worth income calculations during the subject years. ...

For example, he can succeed either by establishing on a balance of probabilities new facts not considered by the Minister showing that he did not earn the unreported income alleged by the Respondent, or by demonstrating that the Minister’s assumptions of fact are wrong. ...

  [26]          Although the appellant managed to show that certain presumptions of fact on which the Minister relied were false, [6] there are still some elements that, when considered together, are not consistent with a contract the company would have entered into if there had been an arm's length relationship with the employee ...

The certainty offered by a court order does not absolve parents of their responsibility to continually ensure that their children receive the appropriate amount of support. 65     In my view, a court order awarding a certain amount of child support must be considered presumptively valid. ...

These circumstances must be taken into account, but must be considered against an objective "reasonably prudent person" standard. ...

Even if the testimony is considered to be reliable, I am not satisfied that it is a reasonable excuse for late filing the 2008 income tax return ...

“Natural person” argument   [21]          The “natural person” argument has already been considered on many occasions by the Tax Court of Canada, the Federal Court of Canada, the Federal Court of Appeal and the Superior Courts and Courts of Appeal of the provinces and by many Provincial Courts ...

Where paragraph (b) is applicable, then the tuition must be paid in respect of a course at least 13 consecutive weeks long. [8]               In four recent decisions, this Court has considered whether individuals taking online courses through the University of Phoenix were enrolled at an educational institution in Canada. [9]               Beaubier J. in Robinson v. ...

There may be deducted in computing a taxpayer's income for a taxation year such of the following amounts as are applicable:   …   (j.04) the total of all amounts each of which is an amount paid in the year by the taxpayer to a registered pension plan as   (i) a repayment under a prescribed statutory provision of an amount received from the plan that   (A) was included under subsection 56(1) in computing the taxpayer's income for a taxation year ending after 1989, and   (B) can reasonably be considered not to have been designated by the taxpayer for the purpose of paragraph (j.2), or   (ii) interest in respect of a repayment referred to in subparagraph (i),   except to the extent that the total was deductible under paragraph 8(1)(m) in computing the taxpayer's income for the year;   (emphasis added)   [10]          In this appeal it is not necessary to determine if all of the conditions for the application of these paragraphs are satisfied as both provisions only apply to amounts paid by the taxpayer. ...

He admits only the following facts stated in the notice of appeal:   (a)     The appellant purchased a parcel of land and a home;   (b)    A structure was built on land owned by the Appellant;   Since the Respondent admitted that the Appellant owned the property and since there was no motion to amend the Reply to withdraw this admission, the property, for the purposes of this appeal, is considered to be owned only by the Appellant. [2] Polley v. ...