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It asserts that the Applicant has not filed any evidence to indicate that she applied for the CRSB or any other related benefit and therefore that this alternative request should not be considered. [19] The document entitled “Confirming CERB, CRB, CRSB and CRCB Eligibility” [CRB Guidelines], sets out the procedure used by CRA officers to determine an applicant’s CRB eligibility, including information that is considered to be acceptable to support an application. [20] The CRB Guidelines state the following with respect to acceptable proof of self‑employment income: ● Invoice for services rendered, for self employed individuals or sub contractors. ...

In view of and having considered these and other authorities and after considering the whole of the evidence and using commercial usage as a guide and confined to the facts of this appeal, in my opinion what has been done and is done by Controlled Foods to the raw materials it uses in the treatments and processes employing the subject machinery, apparatus and equipment would not in fact and generally would not be recognized as constituting the “manufacture or production of goods”, and further Controlled Foods would not be considered and would not be generally recognized as a “manufacturer” or “producer” within the meaning of the Excise Tax Act especially Schedule III thereto. ...

But all these elements have an effect on the price of the shares on the stock exchange, and no doubt they were fully considered by the purchasers of the stock at the then prevailing prices. ... I considered the apparent board lot trades during 1971 as the basis for the calculation. ...

In cases of this kind also, judges have frequently held that while the oral evidence of the taxpayer in court must be considered, his actions at the time of the transaction are often of much greater weight than his oral statements made long afterwards. ... He freely admitted at least one fact that might be considered detrimental, that he had continued to pay his wife a salary of $8,000 a year through all the years of her illness, though she was unable to do any work. ...

In this, three aspects may be considered: 1. The situation where there are only two sources of income, one of them being farming. 2. ... In my view, it should be emphasized that this concept provides only one of the indicia, the weight to be given to which will vary with the evidence adduced in each case. and Without attempting in any way to exhaust the possibilities, some of those criteria which might be considered are the relative amounts of capital investment in the respective sources, the reasonableness of his expectation of profit therefrom, the amounts of gross income and of net income derived from each source, the proportion of time spent in each day by the taxpayer in respect of each source, and the prior history of the respective sources in respect of amount of income generated. ...

Coscarelli submitted to the Court, which she did in a considered and professional manner, given her status as a self-represented litigant without any particular expertise or background either in subject matter or more broadly with legal issues. ... Coscarelli alleges that during a January 2021 call, a CRA officer assured her that the WSIB payments she received in 2019 and 2020 were considered income for the purposes of the Income Requirement. [19] The Respondent counters that the doctrine of legitimate expectation is only relevant when there is clear conduct of a decision-maker with respect to their duty of procedural fairness, and that representations that lead to a legitimate expectation have to relate to procedure and cannot be in conflict with the decision-maker’s statutory duty. ...

In summary, it is my opinion that the objective facts and circumstances of this case, when considered in their true light, corroborate, rather than negate, the sworn testimony of Mrs Esar. ... They were prepared by a reputable firm of chartered accountants who obviously considered the cash basis of income reporting to be the proper basis for these plaintiffs. ...

In each case the true character of the subsidy must be ascertained and in so doing the purpose for which it was granted may properly be considered. Relying on the decision of the House of Lords in The Seaham Harbour Dock Co v Crook (HM Inspector of Taxes) (1931), 16 TC 333, as authority for the proposition that when a payment is made under the authority of an Act of Parliament, the statutory purpose for which such payment is authorized may be considered in determining whether the payment is to be regarded as an item of annual net profit or gain and taxable income in the hands of the recipient, he found the purpose of the subsidy payments could be found in the Act, the agreement and the Orders-in-Council made under its authority. ...

They intended to make County Down their home for the future and had never discussed or considered the possibility of selling it, until after the unexpected problems in its operation developed. ... While these activities are factors to be considered in determining the character of the County Down transaction they are not conclusive in that respect and not inconsistent with the appellant’s position that he constructed County Down as an investment to earn rental income and at the same time to give him and his wife a desirable place in which to live while operating the apartment building. ...

The supermarkets were converting to the self- serve type of meat store and the 1955 contract called for increases in wages and other conditions which the independents considered to be designed more particularly for the self-serve stores than for the family stores. ... His evidence as to his subjective intentions in creating and maintaining them must be considered in the circumstances that existed and along with all other relevant evidence. ...