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NOTE: To be considered an "inordinate amount of time", performing the mental functions necessary for everyday life must take considerably more time than the average person of the same age without an impairment. ... Feeding oneself or dressing oneself, among other things, is considered among the mental functions necessary for everyday life. ... Conclusion   [38]         Having reviewed all the evidence and considered the applicable legislative provisions and case law, I feel that Mr.  ...

Therefore, the place of residence of the employee should not be considered a connecting factor where the question is the location of employment income. ... Shilling argues that the fact that the income is earned as a result of performing services for native people should be considered a connecting factor. ... In my view, if the benefit to a reserve is to be taken into account, the advantage to NLS must be considered to be a factor that connects Ms. ...

Below, I have considered each of the Court of Appeal decisions which have considered Moldowan, supra, and were brought to my attention by counsel. A multitude of Trial Division and Tax Court decisions have also considered subsection 31(1) of the Income Tax Act, 27 of which were brought to my attention by counsel. ... The issue of what constituted a taxpayer’s chief source of income was next considered in the case of MacRae v. ...

In the Tax Court, those facts were considered to be irrelevant to the issues in dispute. ... For all I know, the company and its advisers may well have considered (in initially offering $18,000, and later making further concessions) that the total settlement package covered many more compensable items than mere salary. ... No reasonable inference can be drawn that the company and the defendant considered loss of salary as the sole matter for compensation. ...

The appellant thus acquired supplies at a price which was considered advantageous at the time. ... It cannot be considered in any sense a part of the profit-making structure or organization of an enterprise. ... In my view a payment for the contract must be considered to be a payment for the supply.   ...

Decisions on these issues must be carefully considered as they will profoundly affect the lives of Canadians and all residents of Canada. ... To attempt to do so would trivialize the Charter and inevitably result in ill-considered opinions. ... Each case must be considered on its own facts (or lack thereof). [28]   [39]         In two Charter cases cited by the appellant, R. v. ...

  [48]          As part of the respondent’s argument, it is acknowledged that cheque cashing may be considered a financial service. ...   [51]          Since the supply is a combination of financial and non-financial services, the question of allocation needs to be considered. ...   [98]          In reaching these conclusions, I have considered that none of the supplies likely had a significant marginal cost to the Casinos. ...

Slonim gave detailed evidence regarding the aspects of the IDLS system which he considered to be unique and regarding the uncertainties [2] which in his view flowed from them. ... Slonim identified what he considered to be four major technological advances. ... Slonim was the use of the data driven process which he considered to be relatively new and one which required the use of methodology different from the standard process oriented one. ...

In fact, I can see nothing in the USA that could be considered referable to the existence of a franchise granted by Bost to the Appellant ...   [64]     However, clauses 2.2 and 2.4 to 2.7 of the USA deal with the management of the Appellant and to this extent, the USA may be considered similar to a management agreement. ... Nothing in the agreement shows that the parties considered any of the rights and obligations created by the agreement to be of greater importance than the others. ...

The counter letter...cannot be set up against the respondent and cannot be considered a means of defence against the notice of assessment...;   (C)       CONSTRUCTIONS INTER-BÉTON INC.   38.       ... She considered that the market value of the transferred share of the building corresponded to the municipal evaluation, which was higher than the value of the debt ... This counter letter was considered during the tax collection exercise, very late, such that the Minister could be considered a third person in good faith within the meaning of article 1452 of the Civil Code of Québec, which states:   Art. 1452. ...