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Apart from the owner/operator agreements, I will review the five factors considered by the Supreme Court. ...

The interest liability should not subsequently be considered contingent due to the possibility of a declining real estate market or skyrocketing interest rates. [44]          There is no evidence at the time this provision was agreed to that there were any exceptional circumstances to suggest it was some interest deductibility scam. ...

  [33]     Although Respondent’s counsel made no mention of it, Christie A.C.J. of this Court considered a similar argument in Kennedy v. ...

As to the intention of the parties, a factor considered in Royal Winnipeg Ballet, a list of indicators pointed out by Appellant’s counsel include: Mr. ...

Marie, [1954] S.C.R. 404, this Court considered the case of a municipal tax levied on tenants of land owned by the Crown in right of Canada. ...

  [91]          A person being assessed arbitrarily must, using decisive evidence, not only show how and why the assumptions of fact should be excluded from the analysis but also, and most importantly, establish the facts that should have been considered to support the conclusion that the disputed assessment should be varied or even vacated. ...

The substance of the letter has to be considered. The selection of a case management judge was a procedural issue. ...

Her Majesty the Queen, 93 DTC 791, Bowman T.C.C.J. considered an appeal by a taxpayer who was faced with the task of challenging a net worth assessment issued against his deceased father. ...

Thus, the Appellant is permitted to advance his case and be heard on the merits without waiting until the Minister has considered the Appellant's Notice of Objection. ...

  [140]      He also took exception to what he considered to be a substantial failure on the part of counsel for the Respondent in not asking any questions of the Appellant, when he testified, as to his intentions ...