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., which has always considered and treated them as confidential and is not prepared to allow their use in this appeal without appropriate confidentiality measures; (b) there are confidentiality obligations that have been agreed upon by the Prospector Group and some of its clients, and the fulfilment of those obligations would be irremediably compromised if the Client Contracts were made public in their entirety; (c) the disclosure of information related to the identity of new clients and the rates for the services offered to them would seriously prejudice the Prospector Group's and Prospector Partners' commercial interests; (d) there is a confidentiality obligation imposed by the authors of the Economic Studies the fulfilment of which would be irremediably compromised if the Economic Studies were made public and their authors publically identified; and (e) the Economic Studies contain marketing strategies, market studies and profitability analyses for various products of the Prospector Group and Prospector Partners, which, if they were made public, could enable their competitors to gain a considerable, undue commercial advantage, which would undermine the competitive position of the Prospector Group and the Prospector Partners. 3.   ...

For 2006, the percentage was lower, 35.46%, because she also considered weekend trips across the border to the United States as being personal. ...

This criterion applies if, at the time the property was acquired, the taxpayer had considered the possibility of selling the property for a profit if the long-term investment project could not be achieved for whatever reason ...

In fact, the Minister was satisfied that it was not reasonable to conclude that the appellant and the Payor would have entered into a substantially similar contract of employment if they had been dealing with each other at arm's length, in light of the following facts:   (a)                 The Payor was incorporated on January 1, 2004; (admitted)   (b)                The Payor's business has existed since 1996, when Alphonse Bernard operated his business on his own; (admitted)   (c)                 The Payor's business is an accounting firm; (admitted)   (d)                Alphonse and Claude Bernard have their accounting designations, while Hélène Lagacé has a great deal of accounting experience; (admitted)   (e)                 Alphonse and Claude Bernard are the Payor's only directors, and their sole duty is to approve the financial statements at the end of the year; (denied as written)   (f)                  Each shareholder manages his or her own client base; however, when it comes to purchasing, reorganization or hiring, all shareholders are consulted; (denied)   (g)                 The busiest time for the Payor is between February and the end of May, the income tax return filing period; (denied)   (h)                 The Payor's revenues have been rising steadily for a few years and reached $476,000 in December 2008; (admitted)   (i)                   The Payor employs between seven and eight persons, shareholders included; (admitted)   (j)                  The Payor's business hours, that is, those adhered to by the shareholders, are from 8 a.m. to 4:30 p.m. from Monday to Friday, whereas the employees' schedule is from 8:30 a.m. to 4:30 p.m. for 35 hours a week; (denied as written)   (k)                The appellant was hired by the Payor for the first time during the period at issue; (admitted)   (l)                   The appellant has been retired since October 31, 2008, after 30 years of employment at the Centre de Santé et services sociaux de Baie-des-Chaleurs; (denied as written)   (m)               When she was hired, the appellant had a specific mandate to carry out, that is, to reorganize and standardize the professional staff filing system, update the boilerplate letters and act as a resource person for the secretary/receptionist, who was relatively inexperienced; (admitted)   (n)                 The appellant's work schedule was determined by Alphonse Bernard's because they travelled together; she therefore worked 40 hours a week even though she was paid for 35 hours; (admitted)   (o)                The hours worked by the appellant were not compiled because she was paid a fixed weekly salary and her duties were related to the administration of the business and not directly to operations; (denied as written)   (p)                The appellant's salary was determined at a consultation with shareholders, after a discussion with the appellant on the salary she earned at her former employer and her expectations; (admitted)   (q)                In determining the appellant's salary, the shareholders took into consideration the fact that the work mandate was very specific and limited in time and that once it was completed, the appellant's employment would be terminated and she would not be replaced; they also considered the appellant's experience in the field; (admitted)   (r)                  The appellant received an annual salary of $60,000, which is higher than the three shareholders' base salary without taking into account the bonuses they are paid; (denied as written)   (s)                 The appellant earned $2,307.69 in gross wages every two weeks; (admitted)   (t)                  According to Emploi‑Québec, the hourly wage in Quebec in 2006–2008 for an executive secretary ranged from $16 to $25.99; (denied)   (u)                 For 17 weeks of work, the appellant received $20,399, which corresponds to the annual salary ($20,255) received by an arm's length secretary for a full year of work; (admitted)   (v)                 The appellant was hired primarily to reorganize the filing system during the Payor's busiest period; (denied as written)   (w)               According to the Payor, the appellant's employment was terminated once her mandate was fully completed, whereas the appellant asserts that the termination of her employment corresponds to the fact that the "rush" was over and that she wanted to return to her retirement, despite the fact that the work was not finished because there were still improvements to be made, such as to the archiving policy; (denied as written) ...

Steines’ rebuttal report that address questions that had not been considered when John P.  ...

  [11]     Although the Appellant spoke above of being “responsible” for the Bakery expenses, she took on that obligation voluntarily in the best interest of what she considered a family business operation. ...

MacIntyre never considered selling it in order to buy a comparably priced profitable rental property. ...

The Minister considered that income as business income within the meaning of subsection 9(1) of the ITA. ...

Minister of National Revenue, [1997] 3 C.T.C. 80 at pages 114 to 115: … for a good to be considered “manufactured” by an individual, it had to be given new form, qualities, or properties by the activities of that individual. [38]          This simply did not occur in the present case. ...

  [4]               Together, the payor and the appellant agreed that the appellant would be considered a self-employed worker. ...