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Moriyama and that depends on a number of considerations that have nothing to do with the determination of an amount. ...

No shares other than common shares were outstanding after the IPO; (c)            Alias subsequently issued common shares as a result of private placements, exercise of employee share options, consideration paid for corporate acquisitions and fees for services rendered by third parties, from November of 1990 through the end of Alias's 1993 taxation year. ...

He or she would also consider whether the person claiming to be in business has gone about it in an orderly, businesslike way and in the way that a business person would normally be expected to do. 6               This leads to a further consideration — that of reasonableness. ...

This list is not exhaustive, however. [13]     The evidence showed that the appellant's work was not done under anyone's supervision and that there was no relationship of subordination between her and the payer. [14]     Any agreement or arrangement setting out terms for the payment of remuneration based not on the time or the period during which the paid work is performed but on other objectives, such as taking advantage of the Act's provisions, is not in the nature of a contract of service. [15]     Moreover, there is no room for other considerations such as generosity or accommodation. ...

Being integrated in the operation of the legal office reflects a contract of service. [18]          Taking into consideration all of the circumstances, the Court is of the opinion that the Appellant worked during the period in question for the Payor under a contract of service. ...

There was an item that the Reply did not take into consideration and it has been conceded by the Respondent that there should be $32 additional no matter what, allowed to the Appellant for a massage therapy which was ordered and received and paid for.                   ...

The result might well be different if the agent were simply a friend, professing no particular skill, and assisting the Applicant for no consideration. [12] I have reached my decision in this matter reluctantly, as I would relieve the Applicant from the serious consequences of his agent's mistake if it were open to me to do so. ...

This leads to a further consideration — that of reasonableness. The reasonableness of expenditures is dealt with specifically in section 67 of the Income Tax Act, but it does not exist in a watertight compartment. ...

In all these considerations, it should be kept in mind that no single objective is paramount. ...

Furthermore, the facts do not lend themselves to a consideration of the two recognized exceptions to the general proposition that loans are on capital account, which were enunciated in Easton et al v. ...