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According to defendant's counsel, one should conclude that these certificates of deposit were necessary for the company's operations in participating at fur auctions and should be considered as part of the company's working capital. ... Such an intention, however, must be analyzed or considered in the light of more objective facts gathered through the experience of the defendant's operations from year to year. ... I have considered the matter of costs. I should conclude the parties should bear their own. ...

)   [15]         The Tax Court of Canada has subsequently considered on several occasions the case law cited above. ... Gitman in the De Facto Partnership be considered as an office as defined by the Act? ... Gitman in relation to the estate be considered as an office as defined by the Act? ...

St-Amand, “(A) taxpayer is considered to be responsible for errors made by third parties acting on their behalf for income tax purposes”.   ... The difference between paragraph 30 and the case at hand is, of course, that here every argument put forward by the applicants was considered. ... The discretion could be considered to be fettered if a decision-maker refused to consider arguments because they do not fit neatly within the four corners of the Circular. ...

No. [29]     The Minister's obligations in the pleading of assumptions was considered extensively by Rip, J. in Anchor Pointe Energy Ltd. v. ... (as he then was) considered whether certain franchisees were at "arm's length". ... In that case, the Tax Review Board considered whether there had been a "change in the business" when the taxpayer acquired the marine construction business of its predecessor. ...

Lapointe could reasonably have been considered an employee or an officer of Gératek? ... In our view, there is no evidence that the latter could reasonably have been considered an employee of Gératek. 4.04 Ownership of the tools. ... Thus, 25 per cent cannot be considered as a bonus. It constituted his entire earnings. ...

On the question of compliance with the definition of partnership and whether compliance is necessary in Texas for a person to be considered a partner, there is little evidence. ... Bromberg whether, in formulating his opinion, he considered whether the partnership had a reasonable expectation of profit. ... It is not entirely clear why Professor Bromberg considered the business for profit test to be irrelevant. ...

For these reasons, the SAR cannot be considered separate property. Mr. ... He held the Options right up to the last moment and surrendered them when they were about to expire. (1)     Nature of the Property [70]         The Options were incapable of providing income, often considered a hallmark of capital property. ... This issue was not raised by the parties nor was it considered by the Court. [76]         While subsection 7(3) of the Act deems there to be no benefit when options are disposed of, this deeming provision applies only for the purposes of section 6 of the Act. ...

Boivin, has considered all the information supplied and found that the applicant does not qualify under the Guidelines in Circular 92-2 for the exercise of the discretion of the Minister to waive the interest owed. ... (e) delays in providing information such as the case where the taxpayer could not make the appropriate instalment or arrear payments because the necessary information was not available. and especially, section 10: The following factors will be considered when determining whether or not the Department will cancel or waive interest or penalties: (...) ... Sixsmith, truly considered the particular circumstances of this case. [76]            I would send back the case to CCRA for new decision based on these reasons.                                                                             ...

  [36]                        In this case, the judge considered the Cranswick factors. ... If those factors are considered in light of what I have concluded is the correct construction of the agreement, the Cranswick factors favour the position of the Crown: (a) Did Ms. ... Johnson met the requisite standard of care – that of a wise and prudent person who has considered the matter thoughtfully, deliberately and carefully. ...

  [16]          Both the appellant and his spouse returned occasionally to the Bellechasse area, where they bought a house which they considered their residence or home base ... However, as a general rule, duties will be considered to be of a temporary nature if it can reasonably be expected that they will not provide continuous employment beyond a period of two years. ... When the amount paid by the employer merely compensates for a loss or reimburses an expense incurred as the result of a forced relocation, the amount is not considered a benefit ...