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The Tax Court dismissed William McCutcheon’s appeals and upheld s. 163(2) penalties, finding he was wilfully blind to false business and capital loss claims.
The Appellant's work was not insurable under s.5(1)(a) because there was no contract of service: the Payer exercised no control or supervision, the Appellant provided his own workplace and tools and set his hours, the Appellant did not receive wages and participated in an arrangement to obtain false employment records, and the Appellant failed to rebut the Minister's factual presumptions; accordingly the Minister's decision that the employment was not insurable is upheld.
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