Search - considered

To whatever degree useful, these filings are to be considered an integral part of these reasons. ...

Fibromyalgia was formerly considered to be fibrositis, but recently it has been recognized as chronic pain that is not the result of inflammation. ...

In so reassessing the Appellant, the Minister relied on the following allegations of fact: (a) the Appellant was an employee of Newfoundland Offshore (Nodeco), an employer who was situated at the Bull Arm work site in Newfoundland and was involved in the construction of a gravity based offshore drilling platform for the drilling program Hibernia; (b) the Hibernia work site has been classified as a “special work site” pursuant to a decision of Revenue Canada Taxation, and all duties performed by employees at the site are considered to be of a temporary nature; (c) due to the lack of sufficient accommodations at the work site, employees who agreed to live off the site and to provide their own living accommodations were provided by the employer with an allowance of $40.00 per day for board and lodging; (d) in December 1992, the Appellant’s address, as well as that of his spouse, was P.O. ...

That combined with the fact that they acknowledge that the injury that would give rise to the payments from National Life Assurance Company were work related, the only question is, in my opinion, can the National Life Assurance Company payments be considered to be payments made pursuant to paragraph 5(1) of the R.C.M.P. ...

It was applied to eliminate the loan at the Bank and consequently, cannot be considered as having been received in any year other than 1992. ...

I conclude from the evidence that the Appellant entered into these transactions both because he considered the product to be a marketable one which could produce profits for him, and also for the benefit of the tax deferral which he stood to obtain. ...

Appeal dismissed. mineral resource in Canada including any expense incurred in the course of (A) prospecting, (B) carrying out geological, geophysical or geochemical surveys, (C) drilling by rotary, diamond, percussion or other methods, or (D) trenching, digging test pits and preliminary sampling, but not including (E) any Canadian development expense, or (F) any expense that may reasonably be considered to be related to a mine, whether or not owned by the taxpayer, that has come into production in reasonable commercial quantities or to be related to a potential or actual extension thereof 1 ^This provision reads as follows: 66.1 (6) In this section and sections 66, 66.2 and 66.4, 2 Which reads: 66.1 (6) In this section and sections 66, 66.2 and 66.4, (a) “Canadian exploration expense” of a taxpayer means any outlay or expense made or incurred after May 6, 1974 that is (iii) any expense incurred by him for the purpose of determining the existence, location, extent or quality of a ...

This is a benefit for which the company pays a monthly premium to the Maritime Life Insurance Company and is, under Revenue Canada rules, considered a taxable benefit. ...

In making the reassessments, the Minister considered the following allegations of fact to be true: [TRANSLATION] (a) since 1988, the appellant has always reported rental losses on his condo based on the following income and expenses: TAXATION YEAR GROSS EXPENSES NET LOSS INCOME 1988 $5,600 $14,516 $8,916 1989 $7,075 $13,638 $6,563 1990 $5,105 $16,673 $11,568 1991 $8,104 $18,326 10,222 1992 $6,182 $15,097 8,915 1993 $700 $2,578 $1,878 1993 terminal loss $30,000 (b) the gross income has been declining since the 1991 taxation year; (c) the carrying charges were higher than the gross rental income; (d) the appellant’s primary intention when he acquired the condo was to be able to live there when he retired; (e) the appellant did not do what was necessary to remedy the situation in order to make renting his condo profitable; (f) the appellant invested very little of his own money, since the mortgage was for $110,000, or 95 percent of the cost of the assets; (g) the appellant had no reasonable expectation of making a profit from the rental of real estate during any of the 1991, 1992 and 1993 taxation years; (h) the expenses claimed by the appellant were not incurred for the purpose of gaining or producing income from a business or property, but were rather the appellant’s personal or living expenses; (i) the appellant has not shown that he incurred expenses for the purpose of gaining or producing income from a business or property for the 1991, 1992 and 1993 taxation years; (j) the appellant has not shown that he incurred a terminal loss as a result of selling real estate used for the purpose of gaining or producing income from a business or property for the 1993 taxation year. ...

Analysis and Conclusion: This issue was considered by Judge Rip in Soper v. ...