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  [16]     I accept the testimony of the Appellant’s father and I will allow an adjustment of $5,500 (to reflect amounts re-deposited into the bank account by Jerome and Loretta Terry) in determining the amount of the deposits that should be considered as revenue before the HST is deducted.   ...

  [22]          When assessing whether a finding is reasonable after all the relevant factors have been considered, I must first determine whether all the relevant evidence has really been taken into consideration and, second, whether these facts were assessed appropriately, i.e. whether undue importance was given to some evidence and whether the importance of other facts was undervalued ...

Analysis   [14]          Directors' liability has been considered in several decisions. ...

Issues   [10]     There are two issues to be considered by the Court:   1.                  ...

The husband’s evidence, when considered in toto, does not establish that he suffered on “a continuous basis” during those years ...

Indeed, the Appellants argued that the Minister had not considered this factor in exercising his discretion ...

At least two situations occur to me where a claim by a supplier might be considered:   (a)      where a supplier does not collect GST from a recipient in respect of an exempt or zero-rated supply and then, erroneously, remits from its own funds an amount as GST to the government.   ...

Furthermore, as Judge Mogan said, even if a FMV could be determined, this right would not constitute "consideration given for the property". 28   [49] Not only does this interpretation seem to me to be in greater harmony with the language of section 160 of the Act, but it is unavoidable in light of the interpretative presumption that the law is coherent and systematic. 29 Section 160 must be considered as a whole if we are to determine its scope. ...

Traditionally, if the worker owns or controls the assets and is responsible for their operation and maintenance, he would likely be considered an independent contractor. ...

The Court considered the workers' testimony highly credible.   [6]               The Federal Court of Appeal has on several occasions defined the role conferred by the Act on judges of the Tax Court of Canada. ...