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The following criteria should be considered: the profit and loss experience in past years, the taxpayer’s training, the taxpayer’s intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...

Indeed, the travel agents were guests and did not have to pay. 4.03.3 Counsel for the appellant referred to the John Barnard Photographers Ltd case, where the Honourable L Cardin, Chairman of the then Tax Review Board, allowed the appeal for the expense of a boat which was considered as a commercial boat and had been formerly used by such agencies as the Police Coast Guard: The taxpayer company, engaged in illustrative photography and publishing, decided to create a fishing almanac containing a wide range of features which it hoped to sell primarily to tourists. ...

I see no reason why evidence of facts arising after Valuation Day should not be considered if they were reasonably and substantially predictable on that day and it is a reasonable expectation that the willing seller or purchaser referred to in the definition would have taken them into consideration. ...

They were regarded as good tenants and occupancy by them was considered as protected but if they vacated suite 327, the appellant was most concerned that he might be unable to secure approval of the other condominium owners to new tenants. ...

They will be cited in the analysis as required. 4.02 Commentary and Case Law The Court considered the following commentary and case law: 1. ...

I accept their testimony to the effect that the modification of matrimonial regime and the partition of property had been considered and discussed before the investigation took place on October 13, 1979. ...

By agreement of the parties and with the consent of the Court, the computation of the appellant’s net worth assessments for 1976 to 1978 inclusive, for practical purposes, will be considered here on the assumption that the appellant is the sole proprietor of Riviera Pizza, the understanding being that the decision rendered and the quantum determined in this appeal will apply “mutatis mutandis” to the assessments to be made with respect to the half-interest of the appellant’s wife in Riviera Pizza. ...

Limited as well considered to be the appellant’s interest in the goodwill and business in Doulton products in Canada. ...

Jackett, P considered various possible meanings of control, including de facto control by one or more shareholders whether or not they hold a majority of shares”, and concluded at 303 that “controlled” in section 39 contemplated “the right of control that rests in ownership of such a number of shares as carries with it the right to a majority of the votes in the election of the Board of Directors”. ...

After the appellant’s return for the 1979 taxation year had been accepted as submitted and the appellant had been assessed accordingly, the Department of Revenue notified him, in a registered letter dated January 21, 1981, that only part of the legal expenses deducted, namely $2,363.95, was accepted as an expense, the balance of $12,786.00 being considered a personal expense that could not be deducted in computing his income. 3.04 The amount at issue in the present case is only $12,786. ...