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I have difficulty in accepting volume of work in preparation considered alone, or in conjunction with such factors as the difficulty or importance of the case, as constituting a basis for exercising the judicial discretion to increase Tariff B costs items. ...

Sea Hornet soon found itself unable to carry on business any longer, and there were, of course, no assets to which either Revenue Canada or the Appellant could look for payment. [13] The questions which I must decide are: 1. whether the Appellant, by his conduct, has put himself in such a position that he is properly considered to be a "... person paying... salary or wages... ...

He considered himself to be retired. Grant admitted that by mid-1993 Channel One began to fall behind in its withholding remittances to Revenue Canada. ...

On appeal, the Assistant Director, Appeals Division, provided a letter dated February 4, 1998, stating that John DeBoer was employed under a contract of service and is therefore considered to have been in an employer/employee relationship with H.J. ...

" [14]          Pursuant to both sets of regulations, the value of board, lodging and other benefits received in respect of the employment are not considered as insurable earnings provided no cash remuneration is paid by the employer to the employee. ...

She may have had it prior to the Order and even may be considered to have exercised... it by agreement before the Order. ...

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. ...

She argued that the transfers totalling more than $40,000 are not subject to section 160 of the Act as they were essentially amounts owed and payable to her, and she concluded that she had not benefited from the transfers since she considered them mere repayments. [29]          The appellant also contended that the account was a joint account and thus it could not be concluded that the entire amounts had benefited her. [30]          In that regard, I do not believe that it can be concluded on a preponderance of evidence that it was a joint account. ...

., seven days per week is not supported by any other material fact and in addition, is inconsistent with her application for unemployment insurance benefits [9] in which she stated that during the period from October 15, 1993 to January 31, 1995, she normally worked 44 hours per week, six days a week and earned $921 per week. [14]     The Appellant's reliance on the Records of Employment and the 1995 T4 (Exhibit A-2) is also questionable and must be considered in light of other documents produced by counsel for the Respondent. ...

Where an agent makes a payment on behalf of a purchaser, the purchaser is considered to have paid that consideration and is therefore the only "recipient" of the supply. ...