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.; (b) such portion of each outlay or expense made or incurred as would, but for paragraph (a), have been deductible in computing a taxpayer's income for a taxation year shall be deductible in computing his income for the subsequent year to which it can reasonably be considered to relate;... ... Further, because their primary objective, the inducement of tenants to rent space in the building, was achieved in the year of the expenses, the T.I.P.s were to be considered current expenses. ... In response to T.C.P.L.'s argument that Canderel was wrongly decided because the effect of s. 18(9) of the Act (which requires the amortization of certain prepaid expenses but not T.I.P.s) was not considered, Robertson J.A. began by considering T.C.P.L.'s understanding of the law as it stood before Canderel. ...

Minister of National Revenue (1989), 89 D.T.C. 663 (T.C.C.), considered a number of authorities, including the comments of Fisher, Q.C. in Bloom. ... C.A.), leave to appeal refused [1946] S.C.R. 462 (S.C.C.), Hogg J., considered a number of these cases in determining whether the appellant was a minister as required by the legislation in question. ... Just.), in which the phrase “regular minister of a religious denomination” was considered. ...

He also considered that all mortgages bore reasonable rates of interest, the majority at 6 per cent, with one or two at 514 per cent, two he thought at 614 per cent and one at 7 per cent. ... The multiplicity of transactions, in addition to confirming the foregoing conclusion is also a very strong factor, when considered together with other surrounding circumstances, in determining they were operations of business in carrying out a scheme of profit- making. ... The prospective borrowers or vendors of existing mortgages sought the appellant out and he was in a position to select those he considered most advantageous. ...

On his part, Kostyniuk testified that he felt an obligation to extricate the appellant because he considered it was at his persuasion the appellant bought this land. ... Nevertheless, I accept the appellant’s testimony that he considered this land satisfactory for his plan despite these disadvantages of which he was aware but felt them to be inconsequential. ... Furthermore the real estate agent also considered this land to be “hot”. ...

On that date the appellant and Albany River entered into an agreement (Exhibit 7) by the terms of which the appellant agreed to proceed immediately and at its own expense to examine the ore deposits of Albany River to such extent as it considered advisable; and if the said examination proved satisfactory to the appellant, it agreed to carry out, on or before June 7, 1938, the remaining terms of the agreement. ... In a commercial sense, “asset” means property of one sort or another and I am at a loss to understand how the mere recording of an amount expended in years gone by could be considered as an asset and by itself become the subject of sale and purchase. ... In my view that could not be considered as running into or becoming liable for or subject to, or assuming or contracting for, pre-production expenses; such expenses were not thereby ‘‘incurred’’ by the taxpayer, the appellant. ...

Application of Rule 147(3) Factors [16] The factors set out in subsection 147(3) of the Rules are considered below. (1) Rule 147(3)(a): Result of the Motion [17] The Motion was dismissed, i.e., the Respondent was entirely successful. ... Accordingly, the Respondent takes the position that the issues considered during the hearing of the Motion were of high importance. [24] [21] The Appellant rightly notes that, for the purposes of paragraph 147(3)(c) of the Rules, the relevant question pertains to the importance of the issues raised in the Motion, and not the importance of the issues pertaining to the merits of the Appeal. However, the Appellant does not actually make any submission concerning the importance of the issues considered in the Motion. ...

Furthermore, it also became evident that the Minister overlooked some facts that should have been considered in the ruling. [11] The Appellant performed many tasks for the Payer. ... Non-related persons could also be considered not dealing at arm’s length based on the facts ... The Appellant worked far more hours and performed many more tasks than the Minister considered. ...

McCormick’s notes and decision reports, it is clear that the CRA thoroughly considered Ms. ... In the present case, it is abundantly clear that the CRA referenced, considered, and provided an explanation as to how Ms. ... McCormick considered all of the evidence placed before her and provided Ms. ...

Asgaraly in 2019 (Old Age Security, CPP/QPP benefits, employment insurance benefits, RRSP income, Net Federal Supplement) are not considered employment income and are not eligible for the $5,000 criterion. ... Having considered the factors listed in subsection 400(3) of the Rules, as well as the amount claimed by the AGC, and all other circumstances of that case, I do not find it appropriate to award costs in this case. ... Asgaraly’s supporting documents and having considered the parties’ arguments, I conclude, for all of the foregoing reasons, that the Officer’s Decision is reasonable. ...

That Decision considered the record before the RPD as well as the supplementary arguments and documents on appeal. ... From reading the reasons issued by the RAD, it is clear that the RAD considered the factors referred to by the RPD, namely, the applicant’s level of education, his diverse work experience and his resourcefulness. ... On the other hand, I note that the RAD had also considered other factors and evidence in its IFA analysis. ...