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The meaning of "manufactured or produced" in subsection 27(1) [now 50(1)], which has been considered in numerous cases, also affords no sure guide to what is meant by "manufacture or production" in any other provision, including subparagraph 1(a)(i) of Part XIII of Schedule III. ...

The Queen [1986] 2 C.T.C. 227, Rouleau J. writes, at paragraph 34 (page 18) of his reasons: The contractual issue therefore, cannot be considered to be in some way incidental to the Court's jurisdiction nor is it merely a phase of compulsory execution. ...

If paid to the association, these funds are considered pre-paid expenses, and remain gaming revenues liable to specific accounting, and any surplus remaining after payment of allowable expenses shall be reimbursed to association Members on an equitable basis, on a frequency determined by association membership.                                        ...

In such a case, whether a transaction is abusive will only become apparent when it is considered in the context of the series of which it is a part and the overall result that is achieved (Lipson, at para. 34, per LeBel J.). ...

On the contrary, uncontradicted evidence shows that it is the result of a carefully considered plan executed as conceived. ... In the instant case the evidence negates any such carefully considered plan for the realization of speculative profits. In that respect it also differs from the scheme considered by this Court in Steeves v. ...

The Queen, 80 DTC 6194, [1980] CTC 198 (FCA) Heald, J:—We are all of the opinion that the learned trial judge correctly concluded that the appellant’s antiknock compound cannot be considered to be a “petroleum product’’ as that term is used in paragraph 83(A)(3)(a) of the Income Tax Act, RSC 1952, c 48. ... We also agree with his application of that definition to the facts of this case which resulted in his conclusion that because of the addition of the various substances foreign to petroleum and because of the extensive chemical processes to which the various elements are subjected in the process of producing the antiknock compound, that finished product, cannot, in ordinary parlance, be considered to be a “petroleum product’’ within the meaning of paragraph 83A(3)(a) referred to supra. ...

Finally, he considered the potential profitability of the farm and found that there was “no realistic expectation of a substantial profit”. Thus the learned trial judge considered all factors, and after weighing them together was entitled to reach the conclusion which he did. ...

The respondent further asserts that the letters were not considered by the Minister and therefore cannot be considered by this Court ... It would appear preferably to include the letters in question in the appeal book and leave it to the panel hearing the appeal to determine the relevance of such documents and whether they should have been considered by the respondent. ...

The words “it may reasonably be considered” in subsection 15(1.1) clearly indicate that the evidence of necessary intent can be established if in the circumstances it is reasonable to consider that this was one of the purposes of the payment. ... It did not contain the words “may reasonably be considered that...”. This Court, for purposes of decision, assumed, without finding, that the test was subjective. ... He should instead have considered whether the evidence met the standard of objective reasonability which was required to overcome the onus on the taxpayer of proving that none of the purposes of the payment was a significant alteration of Dr. ...

Each paired Partnerco and Serviceco were considered to be associated with each other by virtue of common control (s. 256(1)(b) of the Act). However, the pair was not considered to be associated with any other pair. ... Instead, the Court should have considered the purpose of the separate existence of two or more corporations. ...