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Federal Commissioner of Taxation [6] that the answer to the question whether an outlay is to be considered capital or current in nature   depends on what the expenditure is calculated to effect from a practical and business point of view rather than upon the juristic classification of the legal rights, if any, secured, employed or exhausted in the process.   ...

You can see that some of them are in a variety of different modes, some of them were painted and finished or [sic] you could be considered finished. ...

  [64]          On the question of due diligence, he considered in his own mind that since the input tax credits from Bell Canada to the numbered company would offset the tax bill, there would be no Goods and Services Taxes owing. ...

  [69]           In the Chrapko case, the Federal Court of Appeal considered both racetracks to be the normal place of work, even though they were some distance apart. ...

  [3]      In order to resolve the question as to whether the five gentlemen are employees or independent contractors, the total relationship of the parties and the combined force of the whole scheme of operations must be considered. ...

  [31]           However, where the taxpayer has not served any written notice that can be considered an objection, there is no support in the case law for finding a valid notice of objection was given ...

  [21]          With respect to the Appellant’s position that there remain documents to be disclosed, I have considered the nature of those documents and concluded that even if the Appellant was successful in her Motion, the potential marginal knowledge that might be unearthed is insufficient to justify any further delay. ...

(iii)             He could do as he pleased within the business of the payer and its subsidiary and take any decisions he considered appropriate. ...

The Appellant further states that the imposition of penalties in the present circumstances represents an arbitrary, capricious and abusive exercise of the Minister’s powers of assessment and, as such, is unlawful and contrary to the Act, considered as a whole ...

She submitted that those therapy‑related expenses should be considered by virtue of paragraph 118.2(2)(1.9) of the Act as therapy expenses and consequently as medical expenses since the therapy‑related supplies were used by the therapists they had hired and since therapy was impossible without the use of those supplies ...