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This specialized service constitutes a composite whole which for the purposes of this Act was correctly considered by the Minister to be a single supply. ...

Canada, 2004 FCA 20); Panini v The Queen, 2006 FCA 224 at paragraph 43. [44]         In drawing the line between “ ordinary ” negligence or neglect and “ gross ” negligence a number of factors have to be considered: a.       ...

Court considered a motion to strike pleadings involving allegations of ministerial conduct relating to an arbitrary seizure of evidence and section 8 Charter violations and abuses during the investigation, audit and assessment processes. [32]   He held that this Court lacks jurisdiction to vacate an assessment based on ministerial conduct in the context of section 8, and subsection 24(1) of the Charter would not provide a remedy. ...

Lalande a salary that was considered by the Corporation’s accountant to be a “big salary.” ...

He stated: 43. . . the law will impute knowledge to a taxpayer who, in circumstances that dictate or strongly suggest that an inquiry should be made with respect to his or her tax situation, refuses or fails to commence such an inquiry without proper justification. [34]         It has been held that in drawing the line between “ordinary” negligence or neglect and “gross” negligence, a number of factors have to be considered: (a)     the magnitude of the omission in relation to the income declared, (b)     the opportunity the taxpayer had to detect the error, (c)      the taxpayer’s education and apparent intelligence, (d)     genuine effort to comply. ...

The corporation was considered to be indebted to the Appellant for these payments. ...

The Minister also varied the reassessments under the ETA to reflect the changes made for income tax purposes. [6]              At the beginning of the trial the respondent stated that all withdrawals, transfers from one bank account to another, cheques, drafts and debit memos made by the appellant from his bank accounts were considered personal expenditures. ...

The “connecting factors” [54]         In Desnomie v R, [1998] 4 CTC 2207 (TCC), Archambault J. considered the following “connecting factors” to analyze whether employment income was “situated on a reserve”: 1.      ...

They cannot succeed in that purpose unless they are considered to be mandatory requirements and strictly enforced. ...

  [35]         According to the auditors- and this Court considered very carefully their arguments- the parasitic businesses under investigation provided credible information regarding the lack of workers. ...