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Each one of these elements considered separately may not be determinant, but the repeated combination of the same factors in four successive transactions cannot but establish a clear secondary intention to resell at a profit. ...

Under that paragraph, the Minister must determine whether those who were responsible for the separate existence of the corporations had, as their sole purpose, the intention that the business of the corporations be carried out in what they considered to be the most effective manner. ...

I conclude that the learned judges considered that the income tax form was sufficiently identified by the letter to become a binding representation of the taxpayer. ...

He considered that the assessments of interest in question were means used by the Minister to recover the sums that he had paid the appellant in 1980 as interest on what was then perceived as tax overpayments. ...

The subsidiary argument that the parent company must be considered a taxpayer within the Income Tax Act because Nassau deducted and remitted to the respondent the withheld tax above mentioned is also untenable. ...

The evidence seems to indicate that niether party to the alleged “agreements” considered that they created binding, legal obligations. ...

Diploma Course in Appraisal or Real Estate Tax Assessment option(s) or successful completion of the Appraisal Institute of Canada (the "AIC") requirements leading to eligibility for accreditation as a Registered Appraiser ("AACI") or other accredited courses considered of equal academic standing. ...

When this application was first considered, as we had doubt that the application should be granted, we gave reasons for judgment on April 22 last [reported [1974] CTC 313] setting out our difficulties and we gave counsel an opportunity to speak to the matter. ...

Canada, 2012 FCA 180, in which a series of itemized repairs were considered collectively rather than individually ...

The plaintiff contends further that the Minister is bound to take account of the facts as they actually are at the time he reconsiders the reassessment on receipt of a notice of objection, including facts not considered by the Court because they did not exist when it rendered judgment and that, if the Minister fails to apply the law to those facts, the taxpayer is entitled to ask the Court to require him to do so. ...