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These are different cases. [59]          In McKay, supra, Ruhl was considered but the Court did not pick up on the issue as to whether or not the vehicle in question was an "automobile" as it has been argued here. ...

., so as to reduce or postpone tax otherwise payable   103. (1) Where the members of a partnership have agreed to share, in a specified proportion, any income or loss of the partnership from any source or from sources in a particular place, as the case may be, or any other amount in respect of any activity of the partnership that is relevant to the computation of the income or taxable income of any of the members thereof, and the principal reason for the agreement may reasonably be considered to be the reduction or postponement of the tax that might otherwise have been or become payable under this Act, the share of each member of the partnership in the income or loss, as the case may be, or in that other amount, is the amount that is reasonable having regard to all the circumstances including the proportions in which the members have agreed to share profits and losses of the partnership from other sources or from sources in other places.   ...

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. ...