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                [6]            This leads to a further consideration — that of reasonableness. ...

Indeed, it was shown that the trust that can exist between a mother and her son had been a positive consideration in entering into a contract of service. ...

These cheques would then be deposited in the Appellant's bank accounts. [14]          The significant cash he saved prior to 1990 was not taken into consideration by the Minister in the net worth assessment. ...

Two other candidates for consideration were submitted, neither was accepted and GRM was replaced as general partner of Pinecrest. ...

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". ...

However, taking into consideration all of the circumstances of this appeal including the testimony of the witnesses, the admissions and the documentary evidence, the Court is satisfied that the Appellant has failed in his onus of establishing, on a balance of probabilities, that he was entitled to the OETC for the 1997 taxation year pursuant to subsection 122.3(1.1) of the Income Tax Act. ...

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.” ...

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.... ...

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". ...

Specifically, the activities undertaken to resolve technical uncertainties are eligible if the taxpayer cannot obtain the solutions through commonly available sources of knowledge and experience in the business context of the firm. [12] In the expert report referred to in paragraph [6] of these Reasons, the small size of the business was taken into consideration but it was concluded that the taxpayer had not gone beyond common software development techniques. [13] The agent for the appellant also argued that the work performed by the appellant constituted experimental development because it was the product of the imagination and inspiration of its designer who, through experimentation, attempted to bring his idea to fruition by drawing on all his knowledge for this project in the technology field. ...