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The Tax Court Judge had considered himself bound by another decision of the Tax Court of Canada in Trynor et al. v. ...

Later on he went to say at page 193:                 For the purposes of the Income Tax Act, therefore, a bad debt may be designated as the whole or a portion of a debt which the creditor, after having personally considered the relevant factors mentioned above in so far as they are applicable to each particular debt, honestly and reasonably determines to be uncollectible at the end of the fiscal year when the determination is required to be made, notwithstanding that subsequent events may transpire under which the debt, or any portion of it, may in fact be collected.                 ...

This seems to me to indicate that the MD considered any operator to remain under the "direction, management and control" of the Appellant. [22]          I noted also in Clause 16 that it was the Appellant who was required to ensure that the assigned operator, who I take it to be the Worker, attend all MD safety meetings. [23]          Clause 18 of the agreement required the Appellant (the contractor) to commence and discontinue work upon the direction of the MD Director of Field Services. ...

RESPONDENT'S SUBMISSIONS: [29]          Counsel for the Respondent agreed that the three factors considered in determining the applicability of issue estoppel were those presented by Appellants' counsel, namely whether the same question arose in two different actions, whether the judicial decision was final and whether the same parties were involved. ...

Papp expressed his views on prescribed versus recommended medicines, suggesting he could use these terms from a medical perspective interchangeably, but for what he considered the legal connotation of "prescription". ...

When personal elements are considered in the search for objective manifestations of the purpose for incurring particular expenses, there should be little need to invoke a reasonable expectation of profit test as a means of introducing objective testing of a taxpayer's purpose in carrying out an activity or incurring an expenditure in pursuit of it. [12] [26]          In addition to the possibility of applying paragraph 18(1)(a) to more closely scrutinize a taxpayer's purpose, more resort in these types of cases might also be had to paragraph 18(1)(h) of the Act which denies the deduction of personal living expenses. ...

Although the appellant maintained that the amount was always considered to be an asset of Conforbel, counsel for the respondent urged me to caution, because the financial statements were not reliable; they had not been audited or even reviewed. ...

The Court will presume that he still had his hearing aid on and that because the father was not looking at him he was not able to understand. [64]          The Court takes into account all of the factors considered here, takes into account the cases, where some were successful and some were not, the Court has to look at them and interpret them in light of the facts given in this particular case. ...

In particular, the appellant argued that there was not a sufficient relationship of subordination between it and the worker for it to be considered an employer for the purposes of subsection 5(1) of the Act. [10]          The respondent, for his part, contended that the worker's internship was insurable under paragraph 6(b) of the Employment Insurance Regulations (" Regulations "), notwithstanding any notion of subordination, as section 6 of the Regulations includes in insurable employment employment which would not otherwise be insurable under subsection 5(1) of the Act alone. [11]          The letter dated May 11, 1998, from CIDA to the president of Mondo-Tech reads in part as follows: [TRANSLATION] We are pleased to advise you that a contribution of CAN $150,000 has been approved for the aforementioned project as part of CIDA's International Youth Internship Program. ...

Decision [15]          There are four periods that can, initially at least, be considered separately in examining whether the Applicant meets the requirements of subsection 167(5). ...