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It must be noted that in agreeing with most of the respondent's disallowances, the Court has taken into consideration the relatively small gross revenues realized by Pearl-Anne's tax preparation business ($4,350 in 1987, $6,110 in 1988 and $7,185 in 1989) and the fact that the respondent has allowed numerous other deductions which were claimed. 4, With respect to the real estate operations carried on by Pearl-Anne (a) The respondent has disallowed the following amounts claimed as "Advertising and Promotion”, namely $1,041 in 1987 (of an amount claimed of $1,320.92), $2,516.16 in 1988 (of an amount claimed of $3,190.16) and $2,877 in 1989 (of an amount claimed of $2,877). ...

On the one hand, account must be taken of the rebuttable presumption that a corporation’s income is business income if that income derives from an activity consistent with its object, and, on the other hand, consideration must be given to the scope of the corporation’s activities which confirms or rebuts this presumption. ...

It is, however, vital that financial transactions be arranged with due consideration to the results thereof from a tax point of view. ...

The appellant’s own learning curve of running a breeding and racing operation by himself must also be factored into the consideration of the Court. ...

A consideration of statements in articles of incorporation regarding the objects of the corporation or restrictions on the businesses it may carry on is not helpful. ...

This was possible only after prior consideration allowing modified insulin amounts to be administered in advance; —Mark was a moderately active child by nature. ...

He now appeals to this Court and alleges that the summary conviction appeal court judge did not give proper consideration to the facts of the case and the grounds of appeal. ...

The appellant’s second argument was that the expenses paid constituted a deductible allowance within the meaning of paragraph 60(b) of the Act. 4.03.2 With respect to the first argument, consideration must be given to paragraph 5 6(1)(b) of the Act which reads as follows: 56. ...

After some further consideration of space requirements, she decided to build a studio at her residence over top of a flat-roofed garage which was attached to the house. ...

There are many factors to be taken into consideration and these have been reiterated in many cases following the Supreme Court of Canada decision in Moldowan, supra. ...