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  [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. ...

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. ...