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If such income is to be considered as income from property, then of course the appellant is entitled to the deduction abatement for provincial taxes permitted by section 33 of the Income Tax Act reproduced supra which here would be $25,278 or 47% X $53,784 (ie, the basic tax, $49,937, obtained by applying $45,070 on the first $90,000 and 65% on the remaining $7,487.47). ... She can only do so if she establishes that such income must be considered as “income earned in a province” within the meaning of the Act and the above Regulations bearing in mind that income from property, even if such property is outside the province, is deemed to be income earned in the province. ... The question, therefore, is whether the benefits received by the appellant under the agreement simply represent a return on capital irrespective of whether such return is based on risk capital or use of capital and should be considered as being essentially and factually passive investment income or whether such benefits must be considered as business income as the source of such income flows from a business operation. ...

He still had income of about $1,000 a month from the sale of the Mill Bay property and his wife was teaching school so he considered that they had sufficient income to complete the building, doing some of the work himself. ... In 1972 he had also bought a house on Prior Street which he considered to be a bargain and intended to fix it up to live in. ... While profits from some of his other real estate dealings were therefore quite properly declared by him and taxed as profits resulting from adventures in the nature of trade, the profits arising from the sale of the subject property should be considered as resulting from the sale of an investment and be considered as capital gains. ...

While the city’s intention to take over the subject property and nearby lots was not public knowledge at the time, he offered all the owners what he considered to be the fair market value in obtaining their options, the prices finally averaging out to about $5,400 per arpent. ... They never considered the possibility of selling even if the services did not come nor did they consider the possibility that they might suffer a loss on the resale of the property in this case. ... He considered that the profit obtained when this property was sold in June 1966 for $310,786 was capital gain. ...

Mr Sorokin had just completed a 28-suite apartment building and had an option on a site he considered suitable for a highrise apartment building. ... It would appear that repayment of the advance of $115,000 made by the plaintiff to acquire the land was not considered to be such a financial obligation. ... If the advance is considered as analogous to a loan it would not be a contribution to the capital cost. ...

The conclusions read as follows: DOTH INCREASE the provisional alimentary allowance aforesaid to $65.00 per week, as a modus vivendi for the support of the Plaintiff and the four minor children of the parties in her custody; and, in addition, Defendant shall pay to the Plaintiff the sum of $33.50 for the hypothec, taxes and the upkeep of the domicile, making a total payment of $98.50 per week to be paid by Defendant to Plaintiff, at her domicile; A final judgment was rendered on October 28, 1969 which does not directly concern the present action which deals only with the 1967 and 1968 taxation years but is of some significance in indicating what the various judges of the Quebec Superior Court who dealt with the matter considered as being the nature of the payments. made. ... It appears to me to be too fine a distinction to state that if the husband had paid this to her and she had then used it to make these hypothecary payments it would all have been considered as alimentary allowance paid to her but merely because the husband made the payments himself direct to the hypothecary creditor it should no longer be so considered, and 1 believe that the justification for refusing to make this fine distinction can perhaps be found in section 16 which none of these judgments appears to have considered. ... Furthermore, as previously indicated, none of these cases considered the possible application of section 16 of the Act or the fact that paragraph 12(1)(b) is specifically excluded from application by paragraph 11(1)(la) both of which paragraphs are in my view significant in determining the true intention of the Act. ...

I gathered from the testimony of the company’s officers that they considered that the program helped to keep the company in business and that the revenue derived was worth the effort, although looked at by itself the leasing of the heaters was not profitable. ... They were considered to be expenses incurred in the company’s efforts to meet and attack the competition from natural gas and to promote sales of fuel oil, and the company felt that it was proper to charge them to current account in the same way as advertising expenses would be so charged. ... The question of deductibility of the expenses must therefore be considered from the standpoint of the company, or its operations, as a practical matter. ...

Such an expenditure must be considered not as part of the cost of carrying on a business, but as part of the cost in acquiring a business. ... Now although the agreements entered into could not be considered as perpetual, Mr Telfer, the appellant’s manager, stated that his company had accepted to pay the purchase price on the basis that it would be reimbursed in twenty years. I would think that such a consideration indicates that the appellant’s advisers considered that the deal would be conducted and completed over a sufficiently long time to give it a certain character of permanence. ...

They considered a 50% interest to the appellant as excessive for his minimal contribution and accordingly reduced that interest to 25%. ... Traders Group considered it to be their moral obligation to compensate the appellant for the appellant’s foregoing whatever right he may have had. ... When the proposal was first considered by the Advisory Committee of Traders Group it was approved in principle. ...

McCormick’s notes and decision reports, it is clear that the CRA thoroughly considered Ms. ... In the present case, it is abundantly clear that the CRA referenced, considered, and provided an explanation as to how Ms. ... McCormick considered all of the evidence placed before her and provided Ms. ...

Asgaraly in 2019 (Old Age Security, CPP/QPP benefits, employment insurance benefits, RRSP income, Net Federal Supplement) are not considered employment income and are not eligible for the $5,000 criterion. ... Having considered the factors listed in subsection 400(3) of the Rules, as well as the amount claimed by the AGC, and all other circumstances of that case, I do not find it appropriate to award costs in this case. ... Asgaraly’s supporting documents and having considered the parties’ arguments, I conclude, for all of the foregoing reasons, that the Officer’s Decision is reasonable. ...