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I am unable to see how the Minister’s revocation of charitable status subsequent to the year of the relevant donation claim can be considered information that calls into question whether the Appellant made payments to Mega Church or any of the other charities to which he claimed to have made donations in 2003 to 2006. ... But, if I were required to consider the question, I would have found that the Minister cannot rely on this type of misrepresentation to justify a reassessment that disallowed charitable donation tax credits. [30] On its face, box 490 of the 2006 T1 Return does not identify the defining features of a person who should be considered to be a “professional tax preparer” for this purpose. ...

Issues [21] Taking into account the parties’ submissions, the Court must determine (A) whether the new evidence (two contracts) and the facts and explanations that were not before the Officer can be considered in the context of the application for judicial review; (B) which standard of review applies; (C) whether Ms. ... These items do not qualify under any of the aforementioned exceptions, so they are not admissible and will not be considered. ...

All things considered, I am of the opinion that the figures, $80,000 on the one hand and $94,290 and $92,443 on the other, presented certain issues. ... Meunier when the suitability of the comparables used by the Agent was questioned because the use made of the lots had not been considered by the Agent. [30] Having regard to the evidence introduced by both parties and this Court’s assessment of that evidence, I am of the opinion that the $90,000 amount at which the first other lots were sold by the Appellant itself is a fair value. ...

The meaning and application of the words “produced or manufactured” were considered by the Supreme Court of Canada in The Queen v Canadian Pacific Railway Company (supra), in which the goods were railway ties that had been impregnated with a creosoting liquid in order to increase their life. ... Attorney General of Canada, [1950] O.R. 429; [1950] C.T.C. 440, McRuer, C.J.H.C. considered the same question in reference to the same statute. ...

., In order to arrive at a value of the subject land, Mr Eldred chose 7 out of 14 vacant land sales in Scarborough which he considered to be comparable to the subject land, taking into account the time of sale, location, size of the property, financial arrangements and the proximity to transportation facilities. ... The prices paid in each case were considered, and suitable adjustments on these prices were made for time of sale, location of comparables, size of parcel, financing, proximity of facilities, Shape and potential, and any other pertinent factors. ...

After considering the low gross income, small acreage and the fact that Mr Zavitz is employed full time, it is our conclusion that he cannot be considered to be farming with any reasonable expectation of a profit.” ... Although Mr Zavitz had considered himself to be farming in the years after inheriting the farm, in the earlier years he had not claimed the farm loss due to advice he had received then. ...

According to the. jurisprudence cited, the different items to be considered are inter alia, time spent, intent, capital committed, profitability of both actual and potential. ... Although the taxpayer was not a full time farmer, his farming activities could hardly be considered a hobby. ...

The defendant suggests as well that the words of the section be given their ordinary grammatical meaning, that they be considered in the light of the intent of Parliament, and be given an interpretation that allows for ease of application. ... At one time, the strict interpretation of revenue statutes was justified on the basis that revenue statutes were considered to have no other governing object other than the collection of taxes: Lord Halsbury, in Tennant v. ...

Defendant's Argument In contrast, the defendant's submission is that the plaintiff's payout to the employee cannot be considered remuneration. ... Counsel for the defendant has submitted that the employer contribution to the purchase of shares cannot be considered remuneration since the employees have not performed any additional service for the benefit of this program. ...

As I understand the teaching profession, positions in the Board Office are considered to be promotions over positions in the schools. ... They are to be considered conjunctively not disjunctively. In the Morrissey case, supra, it was held that, despite extensive time and effort spent by the taxpayer on the farming operation, its profitability was improbable and therefore the Moldowan test had not been satisfied. ...