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The reliability of the evidence is what is paramount.... [14] In this case, reliability is a particular concern because at the time of the hearing, the Relevant Period had commenced nearly 12 years prior and many of the subpoenaed witnesses worked at the Appellant’s premises for only a short period of time. [15] With respect to each fact witness, I have considered all relevant factors [5] and I have concluded that each fact witness is credible. [6] I will address issues of reliability in the context of the evidence. ... They cannot succeed in that purpose unless they are considered to be mandatory requirements and strictly enforced. ... The word “includes” indicates that the List is intended to exemplify the types of forms that may exist but is not exhaustive of those forms. [304] In Caisse populaire Desjardins de l’Est de Drummond v Canada, 2009 SCC 29 (“ Caisse populaire ”), the Court considered the meaning of “security interest” in subsection 224(1.3) of the ITA. ...

Fisher stated at page 17 (D.T.C. 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 uncollectable 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. ...

The federal government considered the money received for the sale of these shares as income and assessed the petitioner for the full amount he received. ... It is essential that all pertinent sections of the federal Income Tax Act should be considered in a matter of this kind. ... In fact, he used the expression “undistributed income on hand of a corporation, which is considered tax-paid”. ...

The entrance hall of 10 feet by 14 feet is not problematic and should be considered. ... To be considered habitable, a basement should at least have finished walls, a ceiling, flooring and electrical wiring (page 5, paragraph 3) ... As a result, the basement cannot be considered a habitable area.   [17]          Even if the basement were considered a habitable area, the addition of the basement and the entrance hall did not double the surface area of the habitable areas of the residence and, more importantly, did not create a new residential complex because the residence remained mostly intact ...

On the contrary, uncontradicted evidence shows that it is the result of a carefully considered plan executed as conceived. ... In the instant case the evidence negates any such carefully considered plan for the realization of speculative profits. In that respect it also differs from the scheme considered by this Court in Steeves v. ...

The first point is that, according to the decision maker, the applicant's previous remittance history was considered in reaching the decision. ... Indeed, I find specifically that it was fair, reasonable and quite appropriate to have considered the one particular instance where he was warned. ... I do not think this decision maker considered any extraneous or relevant factors. ...

I do not think that, in common parlance, the words “product of fish” can be considered as comprehending margarine, even though it contains fish oil as one of its principal ingredients. ... A trade designation in such limited use cannot be considered as of substantial weight in ascertaining the proper description of the goods for the purposes with which we are concerned. ... Therefore, the amending by-law was to be considered as making one enactment together with the original by-law. ...

The Minister instead considered this profit as business income. Accordingly, the carrying over of a capital loss for the same amount for a previous year (1995) was refused. ... At that time, the Minister considered that the Appellant had not demonstrated that he had a reasonable hope of profit and considered the losses as capital losses. ... For one, the Appellant considered himself as operating a business in the field of buying and selling shares since 1986, as he himself indicated in a letter that he attached to all of his tax returns except for that of 2003. ...

The respondent therefore considered the expenses to be personal expenses within the meaning of the Income Tax Act, R.S.C. 1952, c. 148 (am. ... Starting in 1974, as a result of the investment and the appellant's personal 100 per cent involvement in the farming activities, he was considered to be a farmer in the first category until 1986 (paragraph 3.02). Starting in 1987, he was considered to be a farmer in the third category, that is, one whose farming activities did not have a reasonable hope or expectation of profit. 4.02 Analysis With respect to the reasonable hope or expectation of profit, Dickson, J. ...

Taxes, financing cost, etc of the former home before the sale cannot be considered as selling costs. ... In my opinion, they cannot be considered as “in respect of the sale”. Unfortunately, the expenses of $431.79 cannot be considered as deductible. ...