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The remainder of the reduction comprises makeup and hair and wardrobe expenses that were allowed by the Appeals Division because they were considered to have been incurred for business purposes. [10]          Below I set out in more detail the disputed expenses: Taxation Year Category Total Expenses Claimed Total Expenses Allowed 2009 (DE) Advertising $2,566 $2,566   Business Promotion $2,129 $1,006   Makeup/Hair $3,342 $1,671   Management/Chaperone $10,000 $10,000   Research and Development $1,554 —   Rent $2,010 $2,000   Travel $13,957 $4,261   Wardrobe $3,013 $1,506 2010 (DE) Business Promotion $1,378 $347   Makeup/Hair $1,518 $759   Management/Chaperone $14,000 $10,000   Research and Development $463 —   Rent — $4,000   Travel $3,209 $634   Wardrobe $2,659 $1,329 2011 (S) Automobile $2,753 —   CCA Automobile $2,576 —   Makeup/Hair $2,431 $1,251   Entertainment $2,618 $870   Research and Development $2,387 $148   Travel $13,158 $695   Wardrobe $6,414 $3,222 [11]          It should be noted that: –   The 2009 advertising expenses consist of purchases of gifts to the cast and crew of productions Mr. ...

But, the majority went on to find that a constitutional duty was owed, under the head of the “honour of the Crown”, and that the conduct of government officials a century and more ago in respect of the land allocation provided for in the Manitoba Act, 1870, had been so non-diligent as to fail to uphold the honour of the Crown. [19]          The majority then considered whether a Manitoba statutory general limitation provision should apply here, noting the constitutional context. ...

Having considered the entirety of the evidence, it is clear that the purpose of travelling to Thailand was primarily to reap the health benefits of the warm climate. ...

Miller J. reviewed the case law involving gross negligence and the concept of wilful blindness and (at paragraph 65), suggested a list of factors to be considered including 1) the education and experience of the taxpayer, 2) circumstances that would suggest the need or suspicion for an inquiry, 3) the magnitude of the advantage or omission, 4) the blatantness of the false statement or omission and how readily detectable it was, 5) the lack of acknowledgment by the tax preparer in the form itself, 6) unusual requests made by the tax preparer, 7) the tax preparer being previously unknown to the taxpayer, 8) incomprehensible explanations by the tax preparer, 9) the taxpayer makes no enquiry of third parties or the CRA itself. ...

While a failure to inquire may be evidence of recklessness or criminal negligence, as for example, where a failure to inquire is a marked departure from the conduct expected of a reasonable person, wilful blindness is not simply a failure to inquire but, to repeat Professor Stuart’s words, “deliberate ignorance”. [50]   The subjective nature of the wilful blindness standard also means that the personal attributes of the individual may be considered in determining whether the individual is wilfully blind. [51]   In contrast, the objective nature of the gross negligence standard means that the personal attributes of the individual are not relevant unless the individual establishes that he or she is incapable of understanding the risk the individual has failed to avoid (see R. v. ...

Notary Roseline Ménard then suggested that the sale be made in favour of the applicant’s shareholder, Sylvain Simard, who subsequently agreed to act as a nominee for the applicant;   D) The applicant made all the payments for the property located at 157 Pinacle Rd. in Frelighsburg, as was established during the investigation;   E) At all times since December 1, 1999, the applicant considered the property located at 157 Pinacle Rd. as part of its assets, as was established during the investigation;   F) On June 12, 2002, a transaction was concluded between Sylvan Simard and the applicant involving the property at 157 Pinacle Rd. in Frelighsburg, Quebec, as it appears in the sales contract, Exhibit R-5;   G) The transaction filed as Exhibit R-5 was carried out at the request of François Blondin, chartered accountant, after he took over preparing the applicant’s financial statements and noticed that the property that it paid for was not official in its name but, rather, in the name of its shareholder and director, Sylvain Simard;   H) The R-5 contract was drafted for the sole purpose of regularizing a factual situation existing since December 1, 1999, as it appears in paragraph 7 of the R-5 contact;   I) The applicant has owned and occupied the property located at 157 Pinacle Rd. in Frelighsburg, Quebec, since December 1, 1999;   J) At the time of the transfer alleged by the respondent on June 13, 2002, Mr. ...

It appears that De Vries may have considered Houweling to be a shareholder of IPG because he had provided most of the capital for the business. ...

Various avenues for the obtaining of additional financing, including the giving of personal guarantees were considered by the shareholders and directors. ...

If the projects do not meet the criteria that they have to in order to be considered SR&ED activities, the examination will end at that stage. ...

According to Côté, supra, an interpretation can be considered absurd if it leads to ridiculous or frivolous consequences, if it is extremely unreasonable or inequitable, if it is illogical or incoherent, or if it is incompatible with other provisions or with the object of the legislative enactment (at pp. 378-80). ...