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As will be seen from extracts of submissions referred to below, these amounts represented cheques (or cash withdrawals) the details for which were not provided or could not be ascertained and which the auditor considered as further personal expenditures. [10]     The following are extracts from submissions of Mr. ... He didn't give them anything other than this very, what they considered to be, unreasonably low estimate.             ...

  [28]     In Roussy, supra, Linden J.A. held as follows:   7          Hence, the duration of the time a person works is not conclusive in categorizing employment as casual; the length of time may be a factor to be considered, but a more important aspect is whether the employment is "ephemeral" or "transitory" or, if you will, unpredictable and unreliable.  ... In other words, if someone is spasmodically called upon once in a while to do a bit of work for an indeterminate time, that may be considered to be casual work.  ...

  [12]     Considering the low revenues generated by the business, the annual losses and the significance of salary costs in the annual losses, the Minister considered that it was unreasonable to believe that an arm’s length worker would be compensated at such an hourly rate for 43 hours of work per week.   ...   [19]     The Minister considered that the Payer’s low revenues and the significant annual losses he incurred starting in 1997 could not justify hiring an arm’s length worker in the same circumstances.         ...

Several factors can be considered in order to detect the presence or absence of a relationship of subordination. ... Thus, if the Appellant's job meets the requirements of article 2085 of the Civil Code of Québec, it will be considered to have been done under a contract of employment, regardless of the method of remuneration ...

To be considered personal or living expenses, one must answer yes to the first question and no to the second. ... They want me to accept that this involvement of the motorhome is so completely integrated into their business that 100% of its use, and therefore all of its expenses, should be considered business-related. ...

These cases held that expenses claimed or vehicles considered as luxuries (Bentley, Cadillac, Rolls-Royce) were unreasonable expenses. The taxpayers had not shown that in fact their business required the use of a vehicle considered to be a luxury.       ...

(admitted)   (l)         The Appellant claims that, when the worker was considered an employee, the Appellant's truck followed and supervised him and a small group of workers the entire day, supplying them with more ad bags after a few streets, whereas, when he was considered self‑employed, the truck left all the ad bags on one street corner and the worker had to distribute them. ...

If the vast majority considered that an office in-the-home was not necessary, it is not unreasonable to conclude that the decision to maintain an office in the home, was more a personal choice, rather than a requirement of the job. As per fact #25, the payor considered that the workers' hourly rate of remuneration included the workers use of a work station, at their business location.- the majority of workers stated that their only expenses were the cost of bus fare or vehicle expenses incurred to attend at the payor's place of business.- the payor was responsible for bad debts, resolved customer complaints, and was responsible for administering the pre-agreed re-testing after 36 lessons. ...

As you are aware the initial task for me was to determine whether you were considered a "worker" under the Workplace Safety & Insurance Act. ... Moreover, I considered it inappropriate for me to cross-examine Mr. Mount. ...

Each taxation year stands on its own and how the fisc considered a claim in one year is not a binding precedent for other years. ... That does not end the matter, however; it must still be considered whether the impugned provision discriminates against the appellant under the three-stage inquiry articulated in Law. [18]     Applying the analysis set out in Law, it is clear that subsection 118(5) creates a distinction in that it denies equivalent to spouse credits to payers of support while allowing such credits to taxpayers who do not pay support. [19]     Turning to the second stage of the inquiry, the distinction must be based on a personal characteristic that is an enumerated ground under section 15 of the Charter or an analogous ground. ...