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Gourlay, [1975] C.T.C. 297, 75 D.T.C. 5193, [1975] C.T.C. 161 Addy, J: 1 The judgment of the Tax Review Board dated October 6, 1972 is set aside and the matter will be referred back for reassessment of the automobile expenses of the taxpayer for the taxation years 1968 and 1969 on the following basis: 2 The following car expenses shall be considered expenditures incurred for the purpose of earning income— for 1968, 85% of car rental cost and 64% of other expenses; for 1969, 85% of car rental cost and 70% of other expenses. 3 The defendant shall be entitled to costs. ...

He argued that, because of this, the definition of income bonds only contemplated a debtor and a creditor and that, since no payment by a third party can be considered a deemed dividend under subsection 8(3), then any payment by a third party cannot be considered as interest. ... In the circumstances of the present case, interest provided for in the collateral agreement is, as between the parties to the whole transaction, to be considered as interest payable under the whole transaction with the guarantor being considered as included in the transaction. ... Bonus shares or options were obtained in addition to interest where the risk was considered as above average. ...

Unfortunately, your disclosure is invalid given that the disclosure is not considered voluntary. ... Roy concluded that the letter dated September 25, 2015, notifying the applicant that she was the subject of the Audit, was considered a compulsory measure and that the Disclosure could not be considered to meet the voluntariness criterion. ... Martineau’s reference to the Circular is not a problem, as the statements within it were considered guidelines and not prescriptive. ...

Document #7 is a document as described in paragraph 9 of the "affidavit" and is thus considered privileged. ... Document #14 is as described in paragraph 15 of the “affidavit” and is thus to be considered as a privileged document. ... Thus, the above mentioned documents are considered to be documents subject to the solicitor-client privilege. ...

She then considered whether there is a rational connection between the measure adopted and Parliament’s desire to reduce the national debt.  ... Preliminary Remarks             At this point, the specific characteristics of the Income Tax Act should be considered.  ... In the case at bar, Parliament has established the age of 18 as the standard, since at that age children are considered independent and capable of supporting themselves.  ...

I have considered the laws and previous decisions of courts that apply to your case. ... CRA considered your specific circumstances, what Mr Filippazzo told them on your behalf, and what was in their files. ... CRA considered the events during the history of Mr Meleca’s tax filings and compliance. ...

The Tax Review Board considered this amount to be deductible for the purposes of paragraph 60(b). ... It is my considered opinion that the decision of the Court of Appeal as to the nature of the $20,000 for purposes of civil relations between the parties cannot be ignored in establishing the tax nature of this amount. ...

All those facts were considered by the Tax Review Board as appears in the reasons for judgment of the Chairman. ... Had the plaintiff sold all his lots as a result of an unexpected deal to a stranger, such an isolated sale might have been considered as a capital transaction. ...

I cannot accept or understand, under the present circumstances, the allegation made by debtor's counsel that the Quebec Minister of Revenue is to be considered the agent of his federal counterpart and that, therefore, a notice of objection sent to the Quebec Minister of Revenue is to be considered one filed with the Minister of National Revenue. [5]      Therefore, I consider that no valid reason has been put forward by the debtor to halt the execution of certificate IT A-5210-97. ...

In light of the final paragraph of Rule 145 and despite the fact that the Defendants never appeared or filed a defence in the Court record, I considered the bill of costs to be a document served and filed subsequently to the final Court judgment and therefore had to be served to the Defendants with the directions on December 21 ...   [5] The disbursements claimed in the bill of costs are not disputed and are considered necessary to the conduct of this matter. ...