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All monies paid by IT/NET are to be considered as a draw, until IT/NET receives payment from the client. c) If so directed by Revenue Canada policy, IT/NET may perform the function of making deductions at source for Canada Pension Plan and Unemployment Insurance, but not Income Tax. ...

Noël J. made an attempt at defining the elusive concept of custody in Curzi: Some aspects of the definition of the expression "child of the marriage" set out in the Divorce Act evoke a concept similar to the one contemplated by the support obligation set out in the Civil Code: a child may be considered to be under the charge of his or her parents for so long as he or she cannot provide for his or her own needs, regardless of age. ...

The following criteria should be considered: the profit and loss experience in past years, the taxpayer's training, the taxpayer's intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...

Her testimony basically repeated the facts that had been considered in making the determination. [4]            While she qualified some of the facts or fleshed them out with additional details, in general, no new facts were adduced in evidence. [5]            The appellant was very open and straightforward in her testimony. ...

On Saturdays, Sundays and on holidays if no one was in the home and another of the Appellant's operators was in another home in Redvers the operator on duty could leave the home between 11:00 a.m. and 3:00 p.m. if she had no other duties to attend to. [8]            Employment Insurance Regulations 9.1, 10, and 10.1(1) and (2) read: 9.1            Where a person's earnings are paid on an hourly basis, the person is considered to have worked in insurable employment for the number of hours that the person actually worked and for which the person was remunerated.... ...

I considered summoning Mr. Lanthier to show cause why he should not be held in contempt. ...

ISSUES: [2] The main issue is whether in the 1996 and 1997 years the Appellant had a reasonable expectation of profit from the activities of Firebird with the result that he was entitled to the net losses claimed in those years. [3] The Respondent submits an alternative issue namely that if it is determined that there was a reasonable expectation of profit from Firebird's activities the business should be considered as being operated as a partnership with the result that the Appellant and his spouse are each entitled to one-half of the losses claimed by the Appellant in 1996 and 1997. ...

Federal Commissioner of Taxation, 32 A.L.R. 221. [27]          In Zandstra, Heald, J. made the following comments about the nature of a benefit (at page 6419): Applying the above dictionary definitions of "gift" to the facts of these cases, I have concluded that the payments made by these parents to the Jarvis School were not payments made without consideration and cannot therefore be considered "gifts" under section 27(1)(a)(i)..... ...

There was no hard or fast evidence to suggest that there was a reasonable expectation of profit within a reasonable period of time. [36] Further, he questioned whether or not the salary that he drew out of the business could be considered income. ...

The sales that the appellant makes fall into four categories: (a) Sales of cars to the lessee of a leased automobile either during or at the end of the lease in accordance with the option in the leasing agreement; (b) retail sales of cars that are acquired from the lessee during or at the end of the lease and put on the appellant’s used car lot; (c) sales of cars acquired from lessees and “wholesaled” i.e. sent off to a wholesaler where such vehicles are not considered suitable for sale from the appellant’s lot; (d) sales of cars acquired as trade-ins on the lease or sale of another car from the appellant; such cars are either wholesaled or put on the appellant’s lot. [9] It is with cars that fall into category (b) that we are principally concerned in this appeal. [10] During or at the end of a lease, cars may be sold to the lessee or they may be acquired from the lessee, subject to a payment by the lessee or the appellant, depending on the value of the automobile at that point. ...