Search - considered

  [28]          I have considered the points made by Counsel for the Respondent and the points made by Counsel for the Appellant companies and I have concluded that the questions contained in the undertakings in issue are proper questions relevant to the matters in issue. ...

Pursuant to Rule 154, the Taxing Officer, Bruce Preston, should have considered the amounts in issue, the importance and complexity of the issues, and the volume of work;   5.         ...

(Transcript, Volume II, page 78, line 14 to page 81, line 5)   [22]          I have carefully considered the Appellants’ evidence and arguments and the Court decisions to which the Appellant, Andrew Ugro, referred and I have concluded that the Minister was correct in his determination of the net income of Andrew Ugro, for the 2001 taxation year and of the Partnership for the 2002 to 2005 taxation years. ...

  [21]     In Obonsawin, Justice Webb considered the question of quashing a subpoena. ...

Haniff’s testimony, and considered the business records and other financial records put into evidence, I am entirely satisfied that her failure to maintain a cash register or other cash receipt books, sales invoices, purchase invoices or virtually any other financial records for her Glo‑Hair business was done with the specific intention of cheating on her taxes. ...

  [5]               I have also considered the additional information that was submitted by the Applicant and the letter dated February 9, 2011 from Adam Gotfried of the Department of Justice ...

Conclusion   [24]          Based on the facts in evidence in this case, the appellant made false statements or omissions in his 2003, 2004 and 2005 tax returns and the appellant's explanations are not considered credible or corroborated. ...

  [3]               In order to resolve the question before the Court, the total relationship of the parties and the combined force of the whole scheme of operations must be considered. ...

    [39]          This is a question of fact; however, the Courts have developed certain general principles that must be considered when applying the law to the facts of a particular case ...

Since related persons, pursuant to paragraph 251(1)(a) of the ITA, are considered not to be dealing with each other at arm's length, the worker had a non-arm's length relationship with Monica Turcotte as common-law spouse and sole owner of the business she operated as "Bar Le Villageois 2004 Enr. ...