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At the case management hearing on October 28, 2009, counsel for Her Majesty, Vlad Zolia, gave the Tax Court of Canada to understand that Her Majesty considered that the amount Josée Ouellet had paid to the provincial government, that is, $39,858.34, would be subtracted from the amounts Her Majesty was attempting to recover from Josée Ouellet in the above-noted case;   12.       ...

  [28]          In determining whether the Minister had made out his case for penalties in Venne, Strayer, J. considered the particular circumstances of the taxpayer in question noting first “… as it is relevant to the whole question of the application of penalties under sub-section 163(2), that there seems to be a certain element of subjectivity recognized in the case law with respect to assessing the knowledge or gross negligence of a taxpayer with respect to misstatements in his returns: see, e.g., Howell v. ...

And lastly to the following question: "Are you considered to be a resident of another country"? ...

Malenfant’s qualifications and skills; she considered her mature, reliable and responsible since she entrusted her child to her. ...

Wiebe was providing his services to others – including Weststone – at that time but had not registered with GST nor had he considered that he was carrying on his own business. ...

., Tab 12. [16] Document that the appellant gave to the auditor (transcript, page 179, lines 23 to 25). [17] For example, I have difficulty believing that Bruno Dompierre would have no recollection of events leading up to the purchase of the huts if he had been a co-owner (transcript, page 128, lines 18 to 24). [18] Particularly given that it is the lessee who undertakes to comply with clauses 5 to 8 of the lease, including clause 7, which provides that the lessee may not assign his rights or sublet. [19] Although the appellant asked the auditor whether he had considered the possibility that his two sons and he are all owners of the business, the auditor did not make any observations regarding this. [20] The conclusion reached in the rest of these reasons is that, except for a few relatively small changes, the Minister was correct in adding relatively significant amounts to the appellant’s income.   ...

This represented 7.5% of the total funds raised of $2.2 million and the Minister considered that 7.5% was a reasonable financing cost. ...

As for the place of work, it cannot be considered in the traditional way because the work must be performed where the clients are. ...

Because I have determined that the purported transfer of the farm was invalid and legally ineffective, section 245 need not be considered. [42] Respecting whether there was a "disposition" of the farm to his parents in August, 1992, the Appellant stated that the transaction was a valid disposition of land effected by the execution and delivery of prescribed Form I under the Ontario Land Registration Reform Act. ...

If they made a mistake, it was a reasonable mistake that cannot be considered to be neglect or carelessness on their part. ...