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Vuch considered that the Appellant had been grossly negligent in claiming an expense for which he had been reimbursed and not including the same amount in his income. ... Vuch's audit report shows that the truck was considered a recreation vehicle and therefore gave rise to no deduction for the Appellant, which position was accepted by the Appellant's representative at the time (see Exhibit A‑7, pages 3 and 9 of 11) ...

" Clause number two of interim agreement states as follows: "The parties acknowledge and agree that all support payments made by Beth pursuant to the terms of this agreement shall be deductible by Beth as periodic payments includable by David in calculation of their respective incomes for tax purposes and considered as having been paid and received pursuant to the provisions of subsection 56.1(2), 56.1(3), 60.1(2) and 60.1(3) of the Income Tax Act. ... Unfortunately, I have no choice in this particular case based upon the facts and the evidence presented and the interpretation given and the case law that I have considered that the appeal has to be dismissed without costs. ...

The payments will now be considered to be in satisfaction of the purchase price, as opposed to being rent. ... The transfer of a real right in a certain and determinate property, or in several properties considered as a universality, vests the acquirer with the right upon the formation of the contract, even though the property is not delivered immediately [quoique la délivrance n'ait pas lieu immédiatement] and the price remains to be determined.   ...

For Draft Beer, pitchers of beer were considered as the sale item rather than glasses, since pitchers would give a lower projection figure and keep with our conservative approach to the projections. ... R., [8] Bowman J. went on to summarize the factors as follows:   In drawing the line between “ordinary” negligence or neglect and “gross” negligence a number of factors have to be considered. ...

I am at a loss as to how counsel intends to file with this court in such a way that, as regards form, they can be considered a part of the pleadings, free of the comments and exchanges of counsel, answers to demands for particulars. ... That court, addressing the matter of the issues and principles that are to be considered in deciding whether to issue an order for particulars, stated the following:   The principles governing an application of this kind were well stated by Sheppard J.A. in the case of Anglo-Canadian Timber Products Ltd. v. ...

(admitted)   (t)         The voucher that the Appellant submitted to the Minister in support of its $70,000 ITC  claim while the Appellant's net tax return was being considered was issued by Seahawk Investments Ltd., not Seahawk Financial Services Ltd., the alleged supplier referred to in the Notice of Appeal. ... (denied)   (bb)      The voucher which the Appellant submitted to the Minister in support of the $70,000 ITC claim when its net tax return was being considered, and which was issued by Seahawk Investments Ltd., is a fraudulent or false document. ...

This Court has considered the attributes of a "court of competent jurisdiction" on a number of occasions, commencing with its seminal decision in Mills, supra. ... Only where a court or tribunal possesses all three attributes is it considered a "court of competent jurisdiction" for the purpose of ordering the desired Charter relief under s. 24.   ...

Thus, where the nature of a taxpayer’s venture contains elements which suggest that it could be considered a hobby or other personal pursuit, but the venture is undertaken in a sufficiently commercial manner, the venture will be considered a source of income for the purposes of the Act.  53        We emphasize that this “pursuit of profit” source test will only require analysis in situations where there is some personal or hobby element to the activity in question.  ...

Based on the facts obtained in these files, the terms and conditions of the three shareholders' jobs have not significantly changed since they were first considered. ... The Tax Court is justified in interfering with the Minister's determination under subparagraph 3(2)(c)(ii)"by proceeding to review the merits of the Minister's determination "where it is established that the Minister: (i) acted in bad faith or for an improper purpose or motive; (ii) failed to take into account all of the relevant circumstances, as expressly required by paragraph 3(2)(c)(ii); or (iii) took into account an irrelevant factor. [7]     [23]          The important question to be asked in the case at bar is whether the Minister considered all the relevant circumstances required by paragraph 5(3)(b) of the Act. ...

McLeod’s clients’ funds. [20] If the funds were not considered as Mr. ... This is likely because it is already considered payable by the common law ...