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This was done on the advice of his accountant who considered it “reasonable for tax purposes to charge all his expenses on his Thunderbird as business expense” and his wife, in operating Seagull, made no deductions in her tax return. ...

Although there did exist at one time an employer/employee relationship between the appellant and the employer, whatever hesitation I may have had in concluding that the amount of $6,128.55 received by the appellant after he had been dismissed from office was income from employment, completely disappears when section 3 of the Act is considered in conjunction with subsection 6(3) of the Income Tax Act, 1970-71-72, c 63, as amended. ...

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. ...

Suspicious circumstances, therefore, will more often lead to closer scrutiny than those that are in no way suspect. and after discussing the relevant factors to be considered, he went to say at page 226: These quotations suggest that the list of relevant factors is growing and that it may continue to grow. ...

Respondent’s counsel does not appear to have considered whether the Appellant might have achieved some tactical advantage in the presentation of her appeal if she could have prevented Ms. ...

I (d) for greater certainty, no other activity, including working, housekeeping or a social or recreational activity, shall be considered as a basic activity of daily living. ...

If a road of the substance and quality of the New Road was built for the purpose of accessing the site and would later be used to move coal, there would be a good argument that the building of the road was an efficient way of handling both the problem of access to the mine and later removal of the coal and the expenses might well be considered to be CEE. ...

This section provides that: 118.4(1) For the purposes of subsection 6(16), sections 118.2 and 118.3 and this subsection (a) an impairment is prolonged where it has lasted, or may reasonably be expected to last, for a continuous period of at least 12 months; (b) an individual’s ability to perform a basic activity of daily living is markedly restricted only where all or substantially all of the time, even with therapy and the use of appropriate devices and medication, the individual is blind or is unable (or requires an inordinate amount of time) to perform a basic activity of daily living; (c) a basic activity of daily living in relation to an individual means (i) perceiving, thinking and remembering, (ii) feeding and dressing oneself, (iii) speaking so as to be understood, in a quiet setting, by another person familiar with the individual, (iv) hearing so as to understand, in a quiet setting, another person familiar with the individual, (v) eliminating (bowel or bladder functions) or, (vi) walking; and (d) for greater certainty, no other activity, including working, housekeeping or a social or recreational activity, shall be considered as a basic activity of daily living. ...

However, there are affidavits filed on behalf of the petitioners that should be considered. ...

If a justification for the delay is not established, then the question of a remedy must be considered. ...