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Results 2301 - 2310 of 14743 for considered
TCC
Walters v. The Queen, docket 96-2342-IT-G
It is considered to be "one of the nicest farm in the valley." Most of the work was completed by 1991. [10] The breeding barn included good ventilation, stall frames and was considered to be safe to prevent the horses from escaping and injuring themselves. ... He considered himself to be in the general practice of dentistry and does a lot of denture work. ... He worked six to seven hours a day and considered that to be a normal dentist's practice hours. ...
TCC
Hunter v. The Queen, docket 2000-3075(IT)G
No authority is cited for the statement that costs can only be considered from the time litigation is initiated. [30] In Murano et al v. ... It went on to say that factors considered by Revenue Canada included efforts shown to reduce costs and turn a profit and devotion of time to the operation. ... " He also said: "Costs can only be considered from the time litigation is initiated. ...
TCC
Deck v. The Queen, docket 1999-3556-IT-G
A creditor acting reasonably and honestly, must be given some latitude in determining the year in which a debt should first be considered to be a bad debt. ... The prudence of the creditor as a reasonable businessperson in making the determination might be considered as a means of objectifying a determination that might otherwise inappropriately accelerate a loss claim. ... The question of when a debt is to be considered uncollectible is a matter of the taxpayer's own judgment as a prudent businessman. ...
TCC
4145356 Canada Limited v. The Queen, 2010 TCC 613
The classic rule is that evidence may be adduced of foreign law which is considered a fact but not of domestic law. ... Whether the CRA considered applying GAAR or considered applying any other section of the Act that is not referred to in the pleadings is not relevant. ... The questions and answers related to whether the CRA considered applying GAAR are not admissible ...
TCC
Sunatori v. The Queen, 2010 TCC 346 (Informal Procedure)
However, if that was the reason for the Appellant declaring the advances as bad, how can he be said to have personally considered at that time the relevant factors required to be considered in making an honest and reasonable determination as whether the debt was bad? ... The evidence confirms that the repayment of the loans was not considered, let alone analyzed, in this way. ... [13] I have considered several possible scenarios including: Scenario 1. ...
TCC
Werner Blauer v. The Queen, 2007 TCC 706 (Informal Procedure)
Canada (Minister of National Revenue), [4] I considered the meaning of the word “from” in the context of a different issue that arose under the Canada Pension Plan (CPP). ... One such argument I have considered is the drafter’s use of the word “from” as opposed to “for” in subparagraph 115(1)(a)(i). ... It would be exceptional to find that the QPP payments were considered pension payments under the Act and not considered pension payments under a treaty. ...
TCC
Wang v. The Queen, 2008 TCC 308 (Informal Procedure)
He then sat down with the taxpayer and his representative and considered their representations. ... He also considered the screener’s comments. Any one of the three is enough to do a net worth assessment. ... He also considered that the taxpayer was eating the restaurant food and that had to be taken into account ...
TCC
Estate of Rolland Bastien v. The Queen, 2007 TCC 625
The manufacture of moccasins is considered by the Huron community to be a traditional activity. 23. ... It would appear that the Caisse considered that its territory could be larger if it so directed ... the extent to which the investment income may be considered as being derived from economic mainstream activity ...
TCC
Hay v. The Queen, 2004 TCC 51 (Informal Procedure)
Hay cannot be considered a de jure director. Is the appellant a de facto director? ... Hay is not a de jure director, he can be considered a de facto director. ... Indeed, in American jurisprudence, a director has been considered as an officer. ...
TCC
Hunt's Food (1985)Ltd. v. M.N.R., 2004 TCC 58
., supra, the Federal Court of Appeal laid out certain matters which should be considered by this Court when hearing these appeals. ... Nevertheless, they considered it to be his business in fact, albeit not in law ... There were some factors that he considered just superficially and others about which he was mistaken. ...