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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. ...

  [6]      In order to resolve the issue before the Court, the total relationship of the parties and the combined force of the whole scheme of operations must be considered. [1] To this end, the evidence in this matter must be subjected to the four‑in‑one test laid down as points of reference [2] by Lord Wright in Montreal City and adopted by MacGuigan J.A. in Wiebe Door. ...

As the parties considered that they were engaged in an independent contractor relationship and as they acted in a manner that was consistent with this relationship, I do not believe that it was open to the Tax Court Judge to disregard their understanding (compare Montreal v. ...

In other words, the acquisition of the hotel and the lands adjacent thereto was to be considered as a whole, that is to say, as an adventure in the nature of a trade, not an investment project generating an enduring income benefit ...

The appellant explained that the payment of these taxes was considered rent Messrs. ...

We cannot know if the result would have been different if this subsection had been considered by the Court ...