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  [10]         The cross-examination of the auditor did not reveal any anomaly, irregularity or abuse whatsoever in the analysis of the data considered in making the assessments. ... The onus on the Minister will be greater if the taxpayer presents plausible explanations showing a non-taxable source of this additional income.   78      The Minister's burden of proof was considered in J. ...   [45]         The appellants did not in any way challenge the value added to their assets except to submit that the purchase of the licences should have been considered a current expense incurred for the purpose of earning income. ...

I have not even considered the amount of time he spends travelling with the team on away games. ...   [32]     Appellant’s counsel also dealt with the other factors required to be considered in determining the status of a worker ...   [41]     Notwithstanding the weight given to my determination that the Appellant did not carry on a business, I will make further comment, largely by way of summary, on the other factors to be considered. ...

Following a transaction consisting of the sale of a property by the appellant to a corporation in which he holds the majority of the shares, an amount of $523,775 was added to the appellant's income, and this amount is considered by the Minister to be a benefit conferred on a shareholder according to subsection 15(1) of the Income Tax Act ("the Act"). ... Fibers as a special purchaser, which justifies the fact that it paid a price that corresponds to a suitability value and eliminates any cash benefit the appellant may have been considered to have received. [13]     In the cross-examination, Mr. ... Fibers could have considered because, in actual fact, those options had not been considered before deciding to purchase the property. ...

Turning now to the several matters to be considered, in my view, it is the nature of the advantage to be gained which more than any other feature of the particular situation will point to the proper characterization of the expenditure as one of capital or of revenue expense. ... Accordingly, in the submission of the respondent, since there was no certainty that the Cummings would, in the final analysis, have to pay any of the $500,000 and since Domtar had no clear legal right to receive any particular amount from the Cummings, the liability of Cummings as of October 31, 1968, must be considered to be contingent within the meaning of paragraph 12(1)(e) of the Act supra. ... Turning now to the question of the $90,000 commission or finder’s fee paid to the Montreal Trust Company, it is my opinion that this item is in the same category as the 500,000 earlier considered herein. ...

It must also be emphasized that section 67 does not refer to related persons, even though the fact that related persons were involved in this matter was one of the factors that the Minister’s auditor considered in applying that section ... The issue of inconsistent assessments was considered by the Federal Court of Appeal in Hawkes v. ... H.M., this Court considered earlier jurisprudence and confirmed the basic principle that it is the duty of the Minister to assess, and if necessary reassess, taxpayers’ returns so as to apply correctly the law to the facts. ...

Flora was considered to be insolvent by its directors in November 2006.   17.    ... A future event may therefore be considered if it is probable that it will occur and make the debt collectible. [3]   [15]         It seems important to note that it is unnecessary for the creditor to exhaust all possible measures of collection. ...