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It is not practical to find such requests to be objections in the context of section 169. [23]          Accordingly, I dismiss the appeals as requested pursuant to the motions, on the basis that the requirements for 169 have not been met. [24]          Although not strictly part of the judgment, I can add that, although I have not heard any evidence or argument on the merits of this matter, there is a likelihood that, if the merits of this matter had been considered, Revenue Canada's position would have been sustained. ...

All amounts paid to Louise Ouellette or to third parties on her behalf are considered to be part of the maintenance; included in this are expenses relating to the family residence (i.e. mortgage payments, municipal and school taxes, home insurance, electricity, heating, maintenance and cable), expenses relating to various family insurance plans (i.e. life insurance for dependants, survivor pension, hospitalization, medical expenses, paramedical expenses, dental insurance), provincial and federal tax and any other amount that may be agreed on by the two parties (automobile repairs, children's activities fees, etc.). ...

"If on December 31, 1996 you lived outside Canada but you maintained residential ties (as defined on page 5) with Canada, you may be considered a factual resident of a province or territory. ...

Rankin, and the changes in the American tax law had a negative and unexpected impact on the business, no evidence was presented to show what profit the taxpayer might have earned had these events not occurred and whether the amount would have been considered substantial when compared to his professional income. ...

Denis Budgen would not have been considered as holding insurable employment with the appellant, as he was working as an independent contractor. [4] Paragraph 6(g) of the Regulations states the following: 6. ...

    [23]    Robert Gaudreau explained that in determining whether there was a reasonable expectation of profit, the facts of the case, not the element of personal use, were considered: little effort and little profit. ...

Testimony under oath, and cross-examination, have been considered to be the best assurances of the truth of the statements of facts presented. [14] It is the purpose for which the statement is made that is determinative of whether the statement is hearsay. ...

In the alternative counsel submits that even if for some reason the resignation dated February 3, 1993 is found to be ineffective or effective only at a later date he points to the evidence of Joseph that he never considered himself to be a director. ...

[Whether mailing of notice to previous attorney an effective mailing] In this view... it remains to be considered whether the re-assessment under appeal was made within four years from ["the day of an original assessment"]. ...

In making these assessments, the Minister relied on the following facts stated in paragraph 6 of the Reply to the Notice of Appeal: [TRANSLATION] Employment expenses (c) during the years in issue, the appellant was employed by Dessol Paysagiste Limitée (Dessol), of which he is also the president; (admitted) (d) Dessol carries on a landscaping business and its head office is in Hull; (admitted) (e) the appellant's employment with Dessol was seasonal; (f) the appellant received employment insurance benefits during the off-season, that is, from October to April; (admitted) (g) the appellant lives at Blue Sea Lake approximately 100 kilometers from Dessol's place of business; (admitted) (h) according to the T2200 Declaration of Conditions of Employment form for the 1994 and 1995 taxation years, the appellant was required to work away from Dessol's place of business and to pay his own expenses for his motor vehicle; (admitted) (i) the appellant did not keep an appropriate record of his travels and the distances travelled; (admitted) (j) the distances which the appellant travelled between his Blue Sea Lake residence and Dessol's place of business gave rise to personal expenses of the appellant; (k) the appellant claimed employment expenses corresponding to 55 percent and 106 percent of his employment income for the 1994 and 1995 taxation years respectively; (admitted) (l) the appellant claimed automobile operating expenses for the months when he was receiving unemployment insurance benefits; (admitted) (m) the Minister estimates that during the 1994 and 1995 taxation years, the appellant was employed by Dessol half of the year; (n) the Minister further estimates that 50 percent of the appellant's use of his vehicle was for personal purposes during his periods of employment with Dessol; (o) the employment expenses claimed by the appellant and disallowed by the Minister are not reasonable in view of Dessol's sales figures and the fact that he was working for Dessol only approximately six months a year; (p) It is not reasonable for the motor vehicle expenses claimed by the appellant and disallowed by the Minister to be considered as relating solely to his employment with Dessol. [3] I heard the testimony of the appellant and his mother Huguette St-Laurent. ...