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This is also considered to be entered in error. [11] But the real question is whether there was a sale on October 30, when the Appellant and Farm World signed their deal in Form A (Exhibit A-1, Tab 1). ...

Only the first and last of these tests will be considered, the other two posing no problem in this case. ...

The tests to be considered include control, ownership of tools, possibility of profit and risk of loss and integration. ...

It is not practical to find such requests to be objections in the context of section 169. [23]          Accordingly, I dismiss the appeals as requested pursuant to the motions, on the basis that the requirements for 169 have not been met. [24]          Although not strictly part of the judgment, I can add that, although I have not heard any evidence or argument on the merits of this matter, there is a likelihood that, if the merits of this matter had been considered, Revenue Canada's position would have been sustained. ...

All amounts paid to Louise Ouellette or to third parties on her behalf are considered to be part of the maintenance; included in this are expenses relating to the family residence (i.e. mortgage payments, municipal and school taxes, home insurance, electricity, heating, maintenance and cable), expenses relating to various family insurance plans (i.e. life insurance for dependants, survivor pension, hospitalization, medical expenses, paramedical expenses, dental insurance), provincial and federal tax and any other amount that may be agreed on by the two parties (automobile repairs, children's activities fees, etc.). ...

"If on December 31, 1996 you lived outside Canada but you maintained residential ties (as defined on page 5) with Canada, you may be considered a factual resident of a province or territory. ...

Rankin, and the changes in the 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. ...

Denis Budgen would not have been considered as holding insurable employment with the appellant, as he was working as an independent contractor. [4] Paragraph 6(g) of the Regulations states the following: 6. ...

    [23]    Robert Gaudreau explained that in determining whether there was a reasonable expectation of profit, the facts of the case, not the element of personal use, were considered: little effort and little profit. ...

Testimony under oath, and cross-examination, have been considered to be the best assurances of the truth of the statements of facts presented. [14] It is the purpose for which the statement is made that is determinative of whether the statement is hearsay. ...