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This requires an examination in each case of the particular activity and requires consideration of whether there is a genuine profit motive and whether the commercial indicia of the activity are sufficient to constitute it a business. ...

., [1959] S.C.R. 548, [1959] C.T.C. 195, 59 D.T.C. 1119, at page 553 (C.T.C. 202, D.T.C. 1122): In deciding upon the meaning of income, the Courts are faced with practical considerations which do not concern the pure theorist seeking to arrive at some definition of that term.... ...

Rather, the Act contains both objective elements-- embodied in the reasonable person language-- and subjective elements-- inherent in individual considerations like 'skill' and the idea of 'comparable circumstances'. ...

Taking into consideration the evidence heard in these appeals, I am satisfied that Quantum established on a balance of probabilities that it was not in fact a placement or employment agency and that when it entered into the agreements with Mr. ...

He said that the tailings ponds with their perimeter dykes were built to contain the tailings produced by mine extraction and that they were so built with consideration for geo-technical requirements to ensure stability. ...

These, then, are the issues under consideration. Facts [3]            The Applicant's counsel called two witnesses to give evidence in respect of the application. ...

A little further on, he added: [12] Any doubt as to whether the taxpayer’s chief source of income is farming is resolved once consideration is given to the element of profitability. ...

Rather, the Act contains both objective elements – embodied in the reasonable person language – and subjective elements – inherent in individual consideration like "skill" and the idea of "comparable circumstances". ...

" Which necessarily means that for this latter purpose it is legitimate to take into consideration the reasonableness or unreasonableness of any provision of a statute. ...

That in itself is an important consideration militating in favour of the argument that the contract was a contract for services. [1] Ms. ...