Search - considered

However, he found that even if the Carter Commission's recommendations were to be considered, he surmised that Carter intended that the Income Tax Act only deal with debts that were legally forgiven. ...

The defendant had no plans to erect buildings to be retained for rental income on lots in the Spryfield property though I assume it would have done that if it had been able to obtain planning board approval for its development plans and if such a course had then been considered expedient. ...

I have considered those references and they do not, in my view, alter or change in any way, the total thrust of that evidence which is, in my belief, accurately stated by the Board in the passage referred to supra. ...

To the extent I am either not fully understanding CRA's policy or not fully agreeing with it, I have already concluded that, as a matter of law, the two representative agreements in this appeal are providing the Appellant simply with the right to access information via the website for a fee, so the CRA bandwidth policy would not apply in any event. [12]         On that basis, I cannot conclude that, in law, they could be considered payments to the vendors for the lease of equipment. ...

Mr Justice Addy had already concluded the stock option issue against Greiner when he referred to Greiner’s position in connection with another issue which need not be considered here. ...

., [1990] 1 C.T.C. 2432; 90 D.T.C. 1330, in which a subject similar to the instant matter was considered. ...

  [6]      In my view a bad debt cannot be considered to have been written off in a person’s books of account unless and until a notation is made in those books that the particular debt has been written off. ...

In fact it was never suggested to him and he never considered doing so. ...

  [7]                In conducting its review of the authorization under subsection 231.2(6), the Federal Court considered whether, despite the non-disclosure, it should nevertheless uphold it in the interests of verifying compliance with the Act. ...

Having found there was a personal element it was therefore appropriate for him, to then consider whether the Applicant had a reasonable expectation of profit along with other factors such as whether the Applicant had made serious efforts to rent the property. [13]            We are of the view that the Tax Court judge properly considered all of the evidence before him, in making an overall assessment that the Applicant was not carrying on his rental activity in a commercial manner. ...