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  [21]          With respect to the Appellant’s position that there remain documents to be disclosed, I have considered the nature of those documents and concluded that even if the Appellant was successful in her Motion, the potential marginal knowledge that might be unearthed is insufficient to justify any further delay. ...

(iii)             He could do as he pleased within the business of the payer and its subsidiary and take any decisions he considered appropriate. ...

The Appellant further states that the imposition of penalties in the present circumstances represents an arbitrary, capricious and abusive exercise of the Minister’s powers of assessment and, as such, is unlawful and contrary to the Act, considered as a whole ...

She submitted that those therapy‑related expenses should be considered by virtue of paragraph 118.2(2)(1.9) of the Act as therapy expenses and consequently as medical expenses since the therapy‑related supplies were used by the therapists they had hired and since therapy was impossible without the use of those supplies ...

  [18]     The remainder of the increase in the Appellant’s net worth over 2003 and 2004, after deducting the loans of $47,000, would be approximately $25,000, which the Appellant’s representative suggested was small compared to her net worth, and could be considered a “rounding error” ...

  [17]          I have considered those factors and I find that the Appellant and Rupnarain were in partnership with respect to the Burnley Property. ...

Intention   [46]    The intention of the parties has also been considered by the Court. ...

The only objection remaining to CRA’s assessment of the GST is that they considered the full amount charged by the workers in determining her revenue, rather than basing the calculation on the net revenue, after deducting the workers’ payment. ...

Each case must be the subject of a specific analysis, and so the case law must be considered with some reservation ...

the Minister considered all of the relevant facts that were made available to the Minister. ...