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The Court therefore has virtually no information on how the CRA arrived at its initial ruling, what it considered as part of the appeal, whether worker and payor’s interviews and questionnaires were held or obtained, whether Mr.  ...

She did not use her basement for business purposes and its area should not be considered when calculating the percentage of her home that was used for business. [8]               It was the Respondent’s position that the Appellant used a room in her basement for storage of her files. ...

I pointed out at trial that a more reliable estimate of the taxpayer’s income would have been obtained had the auditor used the net worth method or considered all of the deposits in all of the bank accounts of the Appellant and ignored inter-account transfers and bank borrowings. ...

When the CRA received the Adjustment Request, it apparently considered it as legitimate and assessed accordingly. ...

The Tax Court considered a similar issue in the decision of Creagh v. ...

The Queen, [3] the Federal Court of Appeal considered what was required of the Minister in order to discharge the onus with regard to the reassessment beyond the statutory period and the imposition of gross negligence penalties in the case of a net worth assessment. ...

  [22]     I will accept for the moment these properties might be considered Mr.  ...

  [23]          Counsel for the Appellant argues that my colleague Porter D.J. considered a similar EPSP arrangement in Allan A. ...

  [10]     The parties are both in agreement that the definition of “possession” is not defined in the Act, however, was considered by the Federal Court of Appeal in North Shore Health Region v. ...

The money order for $500.00 in April 2003 cannot be considered proof that she donated the full amount of the receipt. ...