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Certainty of intention is a question of construction; the intention is inferred from the nature and manner of the disposition considered as a whole. ... Leigh said that he at no time considered himself to hold his one-third interest in the Property as trustee, and that he considered himself as owner of that interest. ...

  [7]               Once the Minister has established that there is a discrepancy between the taxpayer’s net worth at the end of the year and his net worth at the beginning of the year plus the amount of personal expenditures in the year (but excluding non-taxable income and accretions to the value of existing assets), the burden is then shifted to the taxpayer to establish that the net result should not be considered income from a taxable source (see Bigayan v. ... Her assets and liabilities were considered in net worth as of 2000. All the assets that belonged to her as at December 31, 1999 and that had not been disposed of at the end of the period were not taken into account. ... Therefore, these two transactions were considered in the appellant’s net worth, to his advantage. ...

Having said that, I believe the following factors aught to be considered in trying to measure the reasonableness of these fees.  1.  ... Now there might very well be other factors to be considered, but those are the ones which come to mind in this particular case.  ... She calls all the shots of the hotel and more, and I could go back to my original comments with respect to the factors to be considered in the evidence.  ...

Craig said that he considered himself to be an employee, while Mr. Denholm understood himself to be in business on his own account. ... Two of the drivers called by the respondent to give evidence were asked whether they considered themselves to be in business on their own account. ... Sayle said that he had always considered the drivers to be self‑employed. ...

On October 20, 2000 that office concluded as follows:   … the value of the subject lands, as of December 31, 1971, as outlined in the [Appellant’s] appraisal is considered reasonable.   10.       ... Cushnie used sales of what he considered to be comparable properties. ...   [22]          In Sentinel Hill Productions at paragraph 4, Bowman C.J. outlined the well established principles to be applied in a motion to strike under Rule 53 as follows:   … There are many cases in which the matter has been considered both in this court and the Federal Court of Appeal. ...

The Appellant acknowledged that it is the receipt of a commission that he considered non-taxable, as of the first year, which allowed him to absorb the elevated cost of the universal insurance. ... It appears that in the insurance industry, commissions received upon purchasing personal life insurance policies are considered to be tax-exempt. ... Therein, Wilson J. considered a taxation provision substantially similar to s. 18(1)(a), she examined jurisprudence on s. 18(1)(a), and she came to the following conclusion (at p. 189):   The only thing that matters is that the expenditures were a legitimate expense made in the ordinary course of business with the intention that the company could generate a taxable income some time in the future ...

The table below summarizes the deposit amounts that the Minister considered income, the accounts into which the deposits were made, the expenses disallowed, and the nature of those expenses.  ... Indeed, this explains why certain deposited amounts cannot be considered income ... Thus, no additional income in the respective amounts of $2,318, $80.39, and $12.71, can be considered to have been deposited into the account at the National Bank ...

Second, where extrinsic evidence may be considered, that evidence must pertain to the "surrounding circumstances which were prevalent at the time". ...   [29]          With these principles in mind, I have not considered Mr. ... As well, I have not considered any extrinsic evidence as it is my opinion that the Agreement is not ambiguous ...

Desmeules explained that compensation of all employees was always done by direct deposit to their bank accounts;          (xv) the Appellant always considered the Worker as a supplier and not an employee. ... This means that the Appellant treated the Worker as a supplier not because it considered him as such, but because the Worker did not want to be treated as an employee. ... To determine the nature of a contract of employment in Quebec and distinguish it from a contract for service, the relevant provisions of the Civil Code of Québec (the Civil Code) must be considered, at least since June 1, 2001. ...

  [37]     The Appellant had asked prior to the employment offer in 2004 why he was not recognized as an employee as his readings on the subject had alerted him to the likelihood that at law he would be considered one in any event. ... While the tests considered above were effectively endorsed in that case, they were applied to what was referred to as the central question in making the required determination which was whether the worker was working as a person in business on his own account. ...   [49]     In considering this question I have considered the similarity of the facts in this case with those in Wolf. ...