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Counsel also argued that when a loan is forgiven it need not be part of a severance package for the amount to be considered a benefit arising out of the employer/employee relationship. ...

(ii)                         Rental income – 2000 and 2001 taxation years [14]            The Judge next considered monies earned by the taxpayer in the 2000 and 2001 taxation years in the respective amounts of $5052.80 and $8460.29. ...

The appellant said he considered that a betrayal. This resulted in an intense conflict between the principal shareholders of Relais Nordik Inc. that became known to the main players in the area’s shipping industry and ended up jeopardizing the service contract itself. ...

Additionally, if the respondent [sic] is alleging certain facts in his written or oral argument that were not considered by the respondent in making or preparing the assessment, but which may have an effect on the outcome of the proceeding, he must present evidence of them as in any other civil action. ...

On August 20, 1998, the Minister issued the Appellant a Canada Child Tax Benefit Notice informing her that, until she provides her spouse's name and social insurance number, she would not receive any further Child Tax Benefit payments and that the payment received with respect to July 1998 would be considered an overpayment. *               Partly admitted in Reply but fully admitted at commencement of hearing. [3]            The Appellant was the only witness to testify. ...

  [21]          However, in spite of the breadth of “business”, Heneghan J. ruled that a visa officer’s notes should not be considered records made in the ordinary course of business in Walia v. ...

The Queen 12 to emphasize the importance in tax planning of carefully documenting any particular arrangement. [11]      The Tax Court Judge then considered whether the appellants had "transferred...property" within the meaning of subsection 74.1(2), such that the income from the property must be attributable to each of the appellants. ...

In Henry Wertman v MNR, [1965] 1 Ex CR 629; [1964] CTC 252; 64 DTC 5158, Thurlow, J had occasion to consider the question of whether receipts from the letting of real property are to be considered to be receipts from a business or receipts from property. ...

Among the decisions cited by counsel for the appellant, I also considered the decision of the Supreme Court of Canada in Irving Oil Ltd., Foster Wheeler Ltd. and Canaport Ltd. v. ...

Until they obtain such relief their appeals cannot be considered. I agree with the Chief Justice that Smerchanski’s conduct was such as to disentitle them to such relief in any case. ...