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However, the RAD considered that the RPD did not err on the other points, namely (1) the fact that the complaint to the police station is dated March 24, 2018, and it was recorded as being received at 1:00 p.m. rather than in the evening, which taints the reliability of the document and does not constitute a minor contradiction; (2) the irregularities in the identification number recorded in the complaint, and the fact that the document is limited to repeating the statements without verification or investigation also taints the reliability of the document and its probative value; and (3) the one-and-a-half-month delay in Mr. ... The Minister adds that all elements relating to the refugee protection claim have been considered. ...

The relevant part of the definition applicable to the taxation years at issue reads: “… it can reasonably be considered, having regard to statements or representations made or proposed to be made in connection with the property, that [within a four year period] … the total of all amounts each of which is … represented to be deductible … would equal or exceed [the cost of the property, as adjusted].” ... It is also my view that the representations were of sufficient detail such that it could reasonably be considered that a prospective purchaser could deduct the full purchase price of the Software over a two year period. [21] These issues raise questions of mixed fact and law to which the palpable and overriding error standard of review applies. [22] The valuation report is central to these issues. ...

They did not offer a consideration of when the amounts of expenses, considered generally in relation to gross income and losses, can lead to a determination as to whether or not there exists a reasonable expectation of profit. ... M.N.R., King D.J.T.C.C., in an unreported decision dated June 27, 1991, considered the Amway activity of a teacher/principal in Saskatchewan who reported losses over a long period of time and concluded that no reasonable expectation of profit existed. ...

The law shall be considered as always speaking, and where a matter or thing is expressed in the present tense, it shall be applied to the circumstances as they arise, so that effect may be given to the enactment according to its true spirit, intent and meaning. ... In other words, the passage of time ought to be considered in an interpretative approach so as to preclude integration of these two enactments. ...

The appellant’s position is that the respondent was clearly engaged in tax avoidance when it made those arrangements with Carma and Brinco for the sole purpose of obtaining a reimbursement of part of the tax paid in respect of its 1984 capital gains; that, as a result of those arrangements, the respondent obtained the tax reimbursement he was hoping for; that, according to the jurisprudence, [3] a benefit conferred on a taxpayer within the meaning of subsection 245(2) may consist in a tax advantage; and that the tax benefit obtained by the respondent as a consequence of the arrangements made with Brinco and Carma must be considered as having been obtained from those two companies. ... Appeal dismissed. 1 ‘That provision then read as follows: 245(2) Where the result of one or more sales, exchanges, declarations of trust, or other transactions of any kind whatever is that a person conferred a benefit on a taxpayer, that person shall be deemed to have made a payment to the taxpayer equal to the amount of the benefit conferred, notwithstanding the form or legal effect of the transactions or that one or more other persons were also parties thereto; and,whether or not there was an intention to avoid or evade taxes under this Act, the payment shall, depending upon the circumstances, be (a) included in computing the taxpayer’s income for the purpose of Part I.... 2 That provision then read as follows: 55(1) For the purposes of this subdivision, where the result of one or more sales, exchanges, declarations of trust, or other transactions of any kind whatever is that a taxpayer has disposed of property under circumstances such that he may reasonably be considered to have artificially or unduly (a) reduced the amount of his gain from the disposition, (b) created a loss from the disposition, or (c) increased the amount of his loss from the disposition, the taxpayer’s gain or loss, as the case may be, from the disposition of the property shall be computed as if such reduction, creation or increase, as the case may be, had not occurred. 3 On this point, counsel invoked David v. ...

Two fundamentally different situations may be considered: (a) that in which there is an obligation to pay a weekly sum as alimony which, for whatever reason, is not paid and the cumulative obligation is in fact met by a lump sum or a sum paid as compensation; (b) that in which the agreement itself between the parties provides for the transformation of what in other circumstances could have been an obligation to make periodic payments into an obligation to pay a lump sum. ... It appears that the situation considered in both these decisions as well as in The Queen v. ...

Subsection 188.4(1) reads as follows: (1) For the purposes of subsection 6(16), sections 118.2 and 118.3 and this subsection, (a) an impairment is prolonged where it has lasted, or may reasonably be expected to last, for a continuous period of at least 12 months; (b) an individual’s ability to perform a basic activity of daily living is markedly restricted only where all or substantially all of the time, even with therapy and the use of appropriate devices and medication, the individual is blind or is unable (or requires an inordinate amount of time) to perform a basic activity of daily living; (c) a basic activity of daily living in relation to an individual means (i) perceiving, thinking and remembering, (ii) feeding and dressing oneself, (iii) speaking so as to be understood, in a quiet setting, by another person familiar with the individual, (iv) hearing so as to understand, in a quiet setting, another person familiar with the individual, (v) eliminating (bowel or bladder functions), or (vi) walking; and (d) for greater certainty, no other activity, including working, housekeeping or a social or recreational activity, shall be considered as a basic activity of daily living. ... Work, housework and social and recreational activities are not considered as basic activities of daily living. ...

We do not know therefore at what time the additional amount could have been considered payable pursuant to this amending agreement. ... It can only be considered as an incomplete undertaking. Mr. McMillan is not committed to any specific amount and there is no formula allowing a court to decide what Mrs. ...

The appellant also argues that the failure of the appellant corporation to maintain adequate records should not be considered as an element of fault in determining guilt but should be considered as something which explains the inability of the taxpayer to meet the Minister’s demands. ...

For the purposes of this paragraph the payments made by the husband hereunder shall be considered to be the last income or earnings of the wife and income tax thereon shall be computed accordingly. ... It is therefore quite clear that the amount paid by Gagnon was determinable and was considered by the Supreme Court of Canada as being an "allowance" for purposes of paragraphs 60(b) and 56(1)(b) of the Act. ...