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Severinov filed this appeal before the CRA had considered the notice of objection. ... Severinov may have contributed to this because he filed an appeal before his objection was considered. ...

Savage. [4] In that case the Supreme Court of Canada considered the taxability of a payment of $300 made by an employer to an employee as a reward for the successful completion of certain business related courses. ... Reimbursement for out of pocket expenses incurred as a result of a move, explains NoËl J., cannot be considered a benefit because it adds nothing of value to the recipient’s economic situation. ...

Looking at all of the facts and circumstances in this case, I fail to see how mining and exploration can be considered to be the chief or main or most important element of Sogemines’ business. ... case (supra) expressed agreement with the Tax Appeal Board judgment which considered the following factors: (a) corporate name; (b) corporate purposes and objects as contained in Company’s Letters Patent; (c) the development of its own properties to point of commercial production after an expenditure of over half a million dollars; (d) its general and continuing mining, development and exploring activities during the relevant period; (e) its management contract under which it undertook very serious and extensive mining operations on behalf of several mining companies bringing them to a successful conclusion; (f) the way so many mining companies seemed to turn to Mogul for scientific and technical services as well as for financing help; and (g) its experienced and specialized officers and staff. ...

  [25]          Further, Justice Bowman held that, the Appellant was attending full-time as he was considered a full-time student by the institution and did 22 to 36 hours of course work per week. ... The Queen, 2006 TCC 145, 2006 D.T.C. 2685, Justice Woods held that, for online educational programs to be considered full-time, they need only require the attention of the student on a “full-time” basis. ...

It seems to me that all of the expenditures relating to the investigation of opportunities must be considered on the same footing. ... The Court held at pages 837-38 (D.T.C. 5481): I do not indeed feel that merely because the expenditure was made for the purpose of determining whether to bring into existence a capital asset, it should always be considered as a capital expenditure and, therefore, not deductible. ...

Since an ovum is not an organ, an egg donation cannot be considered to be an "organ transplant". ... Since her reasons, for seeking treatment elsewhere, were completely personal, they cannot be considered in the analysis of the "availability" requirement in paragraphs 118.2(2)(g) and (h). ...

.^ [3] Spar included the foregoing clause in its contract with Com Dev, but also included the following diminution modification clause: 12.7 The information detailed in the Contractor’s letter dated April 19, 1990 is considered proprietary to the Contractor or its Subcontractors as the case may be.^ [4] The letter referred to in clause 12.7 and filed as an exhibit in this proceeding reads as follows: April 19, 1990 File: 5050 Ref.: JB-1578 SPAR Aerospace Satellite and Communications System Division 21025 Trans Canada Highway Ste. ... Statement of Proprietary Information In accordance with the conditions of the RADARSAT Contract between SPAR Aerospace and COM DEV, S-700014, Article 12 — Intellectual Properties — this will certify that all equipments, associated Technical Information and Technical Documentation to be generated in performance of the Work and considered deliverable under the contract will utilize computer software, processes, methods, techniques and know-how in existence or residence with COM DEV prior to effective date of the Contract. ...

These amounts remained unpaid at the end of the years in question, and were considered by the Appellant to be uncollectible. ... The amounts falling into category two, therefore, should properly be considered charges for supplies and services furnished by the Appellant to Hollowforms, and are to be treated as being on revenue account. ...

For that purpose an amount shall not be considered to be payable in a taxation year unless it was paid in the year to the person to whom it was payable or she was entitled in that year to enforce payment thereof (subsection 104(24)). ... M.N.R., [1988] 1 C.T.C. 2398, 88 D.T.C. 1271, Sarchuk, T.C.J. said at page 2401 (D.T.C. 1273): The liability of a taxpayer to pay tax under the Income Tax Act has been considered in a number of cases. ...

  [16]         The appellant insists that his cash donation should be considered separately from the alleged gift of the software licences. ... His alleged cash gift cannot be considered in isolation from the overall plan, which the evidence shows was not properly implemented ...