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Generally, a loan made by a person who is not in the business of lending money is to be considered as an investment. ... The guarantees are to be considered as deferred loans by the plaintiffs to the two companies. When they were called upon to repay, their loss must be considered a capital loss. ...

  [12]            She then summarized what she considered to be the issue and the evidence she considered in coming to her conclusion.  ... Was the Decision Reasonable (Were all Allegations Considered)?   [41]            For the most part, a consideration of whether all of the Applicants’ allegations were considered is subsumed in the adequacy of reasons analysis.  ... The Applicants also argued that the Decision Reviewer should have considered that Ms.  ...

The Minister’s Delegate also considered any limitations on the relief they could consider. ... Bonnybrook did not contest this interpretation. [32] The Minister’s Delegate considered whether the health conditions of Ms. ... Bonnybrook argued that its references to these challenges should have been considered by the Minister’s Delegate. ...

Three cases were referred to by counsel in which subsection 1100(14) has been considered. ... M.N.R., [1985] 1 C.T.C. 2367, 85 D.T.C. 322 (T.C.C.), the same issue was considered involving the same building for a subsequent taxation year. ... (an) important factor to be considered is the proportion of the amount of space rented in relation to the total area of the building. ...

This connecting factor weighs against the refunds being considered as situated on the reserve. 2. ... This would tend to weigh against the rebates being considered as situated on the reserve.      ... All other factors are neutral or weigh in favour of the rebates being considered situated off the reserve. ...

The affidavit explains Ms Taylor’s role as an Appeals Officer and the information she considered in reaching her decision. ... While the latter issue is one of procedural fairness, both issues have been considered together. ... That Memo cryptically sets out the information Ms Taylor considered, but does not suggest that she was advised by the Helpdesk to revoke the applicants’ privileges. ...

We have completed our review and have carefully considered all the information available. ... There is no evidence adduced in this proceeding that permits the Court to determine whether the decision-maker considered the Applicant’s arguments, which facts were considered, or how the decision-maker justifies its decision in light of the facts and the applicable law. ... Its outcome cannot be considered reasonable in light of its serious shortcomings and failure to grapple with the key issue argued by the Applicant. ...

RECOGNIZING that a stay is an injunction, an exceptional discretionary remedy for which an applicant must have “clean hands” to have the application considered by the Court. ... THE COURT ORDERS that, for all these reasons, the applicant’s application not be considered and that the motion be dismissed. ...

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. ...

However, in the absence of any proof that the effect of section 8 of the Canadian Charter of Rights and Freedoms on the validity of subsection 231(4) of the Income Tax Act was considered and dealt with in that judgment, this Court is free to deal with it and applicant brought the present motion with reasonable promptness after such judgment. ... That judgment also considered the possibility of invoking section 1 of the Charter to find that subsection 231(4) is “demonstrably justified in a free and democratic society”. ... This was considered in the Saskatchewan Court of Queen’s Bench by Noble, J in Re Weigel and The Queen, 7 CCC (3d) 82, under section 443 was inadequate so the warrant was quashed, the search and seizure being found unreasonable and in contravention of section 8 of the Canadian Charter of Rights and Freedoms. ...