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I understand that he often referred to legal chicanery that he may have considered bizarre and dilatory; however, his opinion that his administration was completed after February since the only remaining assets were deposit certificates and two immovables is just as bizarre and unfounded. [36] Page 9 of the unaudited financial statements and review engagement reports dated October 7, 1991, indicates that fees of $21,935 were paid to the accountant. ...

During this period he only considered the timber which was of a butt diameter of 12 inches or more. ...

In the submission of counsel for the appellant, what should be considered is the intent of the parties- this was a sale with an intention to repurchase or a sale with a right of redemption. ...

ISSUES: [1] The issues in this appeal, as stated in the Notice of Appeal and Reply to the Notice of Appeal are: (a) whether the Appellant had a reasonable expectation of profit from certain activities carried on by him in the 1991 and 1992 taxation years, and (b) whether the expenses incurred and claimed by the Appellant were incurred for the purpose of gaining or producing income from a business within the meaning of paragraph 18(1)(a) of the Income Tax Act (" Act "). [2] Although the Reply to the Notice of Appeal posed a question as to whether, in the alternative, the expenses claimed were reasonable in the circumstances, no submission was made by Respondent's counsel in that regard and, accordingly, will not be considered in these Reasons. ...

In dismissing the taxpayer’s appeal, the Federal Court of Appeal considered about eight connecting factors and concluded that the taxpayer was engaged not in a business that was integral to the life of his reserve, but in a business that was in the commercial mainstream. [15] In Recalma et al. v. ...

It is the GMS arrangement alone which must be considered. Also, while the relationship between the plaintiff and Marlowe-Yeoman may have been created by contract, it was not an agency contract. ...

The fees they paid to the Company were calculated as follows: 7% to wages 9% to utilities 6% to maintenance 8% to charge cards (they were paid by cheque daily) 50% to products 20% to space rental [28] They considered the joint management operation as a sort of co-op. ...

Inniss can be considered to have been acting as an independent contractor on that basis. ...

Both denied the allegations. [14] I have considered the testimony of Noss and Scolaro, their relationship with the Appellant, their attitude, the manner in which they testified, as well as the probability of the facts they have sworn to and have concluded that where there is a conflict, I accept their testimony over that of the Appellant. ...

By questioning not the relevance or truth of the facts relied upon by the Minister but simply the weight to be attached to the various facts otherwise properly considered, the Tax Court Judge, in effect, overruled the Minister’s discretionary determination without first having concluded that the determination had been made in a manner contrary to law.... ...