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Tax J. 476 at page 487, as to the policy considerations involved: Any requirement of conformity between financial statements and income tax accounting is undesirable basically for two reasons. ...

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'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. ...

He also said consideration was given to the use of the plant for the manufacture of paint, for warehousing and as a location to which the plaintiff's Manitoba formulating enterprise might be transferred. ...

It must be answered having regard to the facts of the particular case and the weight which must be given to a particular circumstance must depend upon practical considerations. ...

(at 353)       [59]            The Court makes clear that the analysis to determine whether a question is moot “ requires a consideration of whether there remains a live controversy.” ...

If they do not, it is necessary to go on to determine whether the normal course dividends are included in the ATCOR/Forest series of transactions by reason of subsection 248(10). [49] Determining whether a series exists at common law involves a consideration of how closely tied individual steps or transactions must be to constitute a series. ...

Feener, [1921] 62 S.C.R. 534 at p. 540: The object of the Court in construing a contract must be to ascertain and give effect to the intention of the parties gathered from the contract as a whole – not from a consideration of a single provision divorced from its context ...

There does not appear to have been any consideration given in any of the jurisprudence to which I was referred to the meaning of the word “source”. ...

The circumstances must be examined as a whole, but it is nevertheless obvious that considerations based on the personal acts of the individual must receive special attention. ...

The question at this stage is whether the taxpayer can establish an intention to make a profit, whether or not he was motivated by tax considerations.  ...