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The sections of the Act particularly to be considered in this case are Section 6(f) which provides: “6. ... While there is force in this contention there are other facts to be considered. ... This was because he considered that dairy cattle could do better and he could obtain milk revenue while he was building up his herd. ...

The decision also states that remission and relief are granted through separate mechanisms; therefore, remission is only considered in rare and extraordinary circumstances. ... The reviewing court is therefore not to substitute its assessment of the merits by re-examining the evidence and thereby substitute itself for the administrative decision maker. [33] The decision is reasonable given that the decision maker considered the case on the basis of the guidelines in the Remissions Manual for Canada Revenue Agency employees. ... In fact, the applicant has not invoked any other factors that could be considered. [42] Here, the decision is not arbitrary. ...

Thus, where the nature of a taxpayer’s venture contains elements which suggest that it could be considered a hobby or other personal pursuit, but the venture is undertaken in a sufficiently commercial manner, the venture will be considered a source of income for the purposes of the Act. 53 We emphasize that this “pursuit of profit” source test will only require analysis in situations where there is some personal or hobby element to the activity in question. ... We would also emphasize that although the reasonable expectation of profit is a factor to be considered at this stage, it is not the only factor, nor is it conclusive. ... Paletta indicates that all the evidence must be considered because what may appear to be commercial activity may not in fact be conducted with the intention of making a profit: “where... the evidence reveals that, despite the appearances of commerciality, the activity is not in fact conducted with a view to profit, a business or property source cannot be found to exist.” ...

Desautels in his initial application and considered the first officer’s notes, as well as all the documents filed by the applicant. ... Desautels suffered a drop in income of more than 50% in the last 12 months, since, in the absence of a bank statement, it is impossible to determine whether he received eligible income. [52] In my view, the record shows that the second officer considered all the documents and information Mr. ... Desautels’ supporting documents and having considered the parties’ arguments, I conclude, for all of the foregoing reasons, that the second officer’s decision is reasonable. ...

The Officer considered all documentation submitted by the Applicant and determined it insufficient to support the Applicant’s eligibility for the benefits. ... Further, the Applicant was advised by letter dated July 25, 2022 that disability benefits were not considered employment or self-employment income. [29] In light of the limited information provided by the Applicant to support that she had earned $5,000 in employment income as required by legislation, I cannot find the Officer’s decisions unreasonable. ... This was not, however, a reason advanced by the Officer for determining that the Applicant was ineligible for the benefits and, therefore, was not considered by the Court: Beddows v Canada (Attorney General), 2023 FC 919 at para 128. [32] Finally, the Applicant raises a new issue before this Court, namely that she had a total reported income of $8,501 in the 2021 taxation year: Applicant’s Memorandum of Fact and Law at para 12. ...

Grandmont is of the opinion that the evidence and arguments she sent to the CRA were misinterpreted, unfairly considered inadmissible, and taken out of context. ... Here, the Officer expressly considered the comments and documentary evidence submitted by Ms. ... Grandmont’s case, the record shows that the Officer followed rational, coherent and logical reasoning in her analysis, and that she considered Ms. ...

Although the purchase price was considered adequate Mr David Friedman, who was sixty-four years old at the time, and his brother Hyman, who I understand was older, did not accept the condition by which the twenty-year lease would be personally secured. by the appellants. ... Counsel for the appellants, on the other hand, is asking that the Board find that the offer to purchase the subject property at a price of $1,500,000, dated October 22, 1971, (Exhibit A-1) be considered as indicative of the fair market value of the property as at December 31, 1971. ... Since the offer to purchase the property in 1971 was made by an informed purchaser, it is logical to suppose that the prospective buyer considered that the replacement cost of the property was $1,500,000. ...

Perhaps it could be considered that the amounts were rather arbitrary, particularly in that they were specifically geared to pay a mortgage payment on his personal residence. ... Obviously, there is no definition in the Circular for small amounts, and whether or not the payments in question can be considered small amounts, it’s not up to us to determine that. ... Consequently, in this case, Mrs Latta has included one third of the lease payment in her income on her T4 slip as a taxable benefit, which is the minimum standby charge as provided for in the Act, and I would submit that any taxable benefits that could be construed in this situation should be taxed in the hands of Mrs Latta, and that they not be considered loans to Mr Latta by the company. ...

His concern was not so much whether the contracts were bona fide contracts but, assuming them to be bona fide, how much of a pay-out would be considered reasonable by the Tax Department. ... In subsequent evidence at the hearing before me I was told that the 1976 value would have been $790,000 in the case of Flanagan and $480,000 in the case of Burroughs had appropriate tax implications been considered. ... I agree with counsel for the plaintiff that it is not impossible that Flanagan might have agreed to the settlement in such an event but it simply points out, once again, to me at least, that Flanagan never considered the agreements as employment contracts but simply as negotiating devices. ...

.: — It was agreed at the outset that the two matters would be heard at the same time and the evidence would be considered in each appeal where relevant. ... At first the figure was allotted among all six shareholders but then it was considered to be an expense of the three plaintiffs only and the benefit was allotted among them. ... There was no distribution of assets that could be considered to be the deemed benefit. ...