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McMillan went on to say that the CBSA was unable to “process” the Applicant’s request because the “appeal is considered to be invalid”. [37] The Applicant seeks judicial review of the Decision of the CBSA as set out in its letter dated May 17, 2019. ... Unfortunately, we are not able to process your request as your appeal is considered to be invalid for the following reasons: 1. ... Furthermore, an application for extension of time under section 60.1 cannot be considered as any application would have had to have been made within one year after the expiry of the time set out in section 60. ...

Counsel for the Minister emphasized instances in which he considered that the express terms of the contracts were ignored. ... It is true that Independent’s source of income was from its management contract with Campbell Ltd. but in the meantime Independent had built up liquid assets which would permit of it paying greater salaries than those budgeted for if it considered it expedient to do so. ... C.R. 408; [1969] C.T.C. 533, Gibson, J. considered on the evidence before him that the transaction there involved was a sham which the parties never intended to be acted upon and that Section 137 therefore applied. ...

Seeing that no notice was given, it is clear that the objection to the jurisdiction must be considered in these proceedings. ... Under such circumstances, it does not seem to me that Atlas can be considered as a stranger to this litigation. ... In my opinion Atlas must be considered as the real claimant against Her Majesty and as having sought from the Supreme Court of Ontario a finding on which to base that claim. ...

The proposal was considered at a meeting of the directors of the appellant and several factors entered into their decision. ... These were difficulties which could be overcome but providing the bond was considered to be something of a burden. ... There is much more to the picture than that and in reaching a conclusion the other features of the situation must be considered as well. ...

Since the party with whom he was concerned held only 50 per cent of the shares he concluded that the party could not be considered as controlling the company ‘‘notwithstanding the articles of association adopted by the appellant which gives its president a preponderant vote in the case of the equality of votes at every general meeting of the company’’. ... While my brother Thurlow readily conceded that on the question of a casting vote in the event of an equality of votes opinions might differ, nevertheless, he has expressed strong doubts that a casting vote can be considered control at all and even if it could, that it can be considered within the meaning of the word ‘‘controlled’’ in Section 39 of the Income Tax Act. ... On the authority of the Bibby case, [1945] 1 All E.R. 667, the share held by William Jager in trust is to be considered as being held by him and enquiry is not to be made as to the beneficial ownership thereof. ...

Robinette submitted that as the mortgages were bought to keep and not to sell, the transactions could not be considered as trading or as an adventure in the nature of trade. ... The mortgages in question bore what he considered a fair return on his investments. ... Peter Dixon & Son, Ltd., 25 T.C. 358, the Court of Appeal considered the nature of discounts and premiums received by the taxpayer from a subsidiary company which it had established in Finland. ...

,The hogs were sold and the proceeds of their sale in excess of their cost were considered as a reduction in the cost of butter manufacture. ... He considered this to be a first payment on his poultry. On March 1, 1949, he received another statement showing the grade of the poultry delivered by him, the number of pounds, the price, and the value, which came to $38.55. ... McPhail meant his own produce and that of his neighbours who were members of the association and, while he had no contract whereby the property in his produce continued to be his and expected only money in return for it, he considered that the net proceeds of its sale was his. ...

Question 2: Were international tax measures considered as part of the Technical Committee’s mandate? ... Question 3: Were the FAPI rules considered as part of the Technical Committee’s mandate? ... Question 4: Were the transfer pricing rules considered as part of the Technical Committee’s mandate? ...

These articles thus also are not admissible. [22] Although the 2009 letter to the CRA and the post-Decisions correspondence might be considered background information in their most favourable light, in my view they do not add anything new. ... The Decisions were not unreasonable [39] I find that the Applicants essentially request the Court to reweigh and reassess the evidence considered by the third reviewer. ... : Vavilov, above at para 97, citing Komolafe v Canada (Minister of Citizenship and Immigration), 2013 FC 431 at para 11. [42] Having considered the Decisions and underlying Third-level Taxpayer Relief Fact Sheets [Fact Sheets] carefully, I conclude that they do not disclose a reviewable error warranting the Court’s intervention. ...

That said, the receipts and their contents will not be considered by the Court in analyzing the substantive issues that the Officer was mandated to decide. ... However, the Officer does not explain why the receipts, which she did not review, do not correspond to the wide range of documents considered “acceptable” under the guidelines. ... The Officer’s report does not demonstrate that the CRA carefully reviewed and considered Mr. ...