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Pat Paletta considered the reporting of the trades thoughtfully, obtained professional advice on the proper reporting of the trades, and relied on his longstanding and trusted accountants to prepare his returns. ... Angelo Paletta testified that his father was “a wizard with numbers” and “had a computer brain”. [203] [266] Before leaving the statute-barred issue, I have carefully considered whether the carry over of a portion of the overstated 2002 loss to the 2005 taxation year under section 111 of the Act was attributable to carelessness or neglect on the part of Mr. ... Since it is a subjective test, the personal attributes of the individual may be considered in determining whether the individual is wilfully blind. [116] On the other hand, the “gross negligence” standard is an objective test. ...

There is no suggestion in his reasons that it could have been considered an invitation to enter without showing her the search warrant. [67] Both RCMP officers then entered the house to satisfy themselves there were no threats to the investigators’ safety. The CRA Criminal Investigations’ investigators then entered and search the house and seized a number of documents. [68] Judge Gouge then considered the requirements of section 29(1) of the Criminal Code which provides: “It is the duty of everyone who executes a process or warrant to have it with him, where it is feasible to do so, and to produce it when requested to do so” « Quiconque exécute un acte judiciaire ou un mandat est tenu de l’avoir sur soi, si la chose est possible, et de le produire lorsque demande lui en est faite » [69] When asked by Judge Gouge why she did not give Ms. ... Informer privilege precluded the McCarties having this information. [4] The possibility of amicus curiae was also considered, but was found to be precluded by valid precedent. [5] Note Mr. ...

The appellant never considered the money deposited into her bank account as her property and in that respect she is not the “transferee” of the alleged “transfer of property;”   16.     ...

After Justice Webb provided a review of the relevant jurisprudence in LeCaine, his summary referred only to the probability or improbability of an event as a factor to be considered by a judge in assessing the evidence but not to any degree of heightened onus within the standard of the balance of probabilities itself, as Appellant Counsel proposed. ...

He considered it to be a conclusion of law "that has no place among the Minister's assumed facts". [25]       I agree that legal statements or conclusions have no place in the recitation of the Minister's factual assumptions. ...

At paragraphs 4, 5 and 6 of his reasons, Justice Fournier writes as follows:   [T ranslation]   [4]        For instance, in the case of civil liability litigation, the written or verbal offer to pay a sum of money cannot be used against the person who made the offer and as such is considered covered by the solicitor-client privilege. [5]        However, in the course of negotiations, counsel’s very mandate for settlement purposes is to state his or her client’s position. ...

  [25]          Counsel for the Respondent states that both the Aztec and Kovacevic cases were concerned with applications to extend time for filing Notices of Objection and should not be considered as applicable in this matter but I do not agree. ...

Had he considered Mr. Cole's evidence, as he was bound to, he would necessarily have concluded, in my view, that the appellant had made a prima facie case "demolishing" the Minister's assumptions. ...

Cribari with no explanation and accordingly such amount cannot be considered advanced in this deal. ...

Mooty stated that they had begun pursuing this acquisition in 1979 and they had considered nothing other than combining the OJC and DQC operations because it made no sense whatever to have the American company running a separate operation in Canada. ...