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He then sat down with the taxpayer and his representative and considered their representations. ... He also considered the screener’s comments. Any one of the three is enough to do a net worth assessment. ... He also considered that the taxpayer was eating the restaurant food and that had to be taken into account ...

The manufacture of moccasins is considered by the Huron community to be a traditional activity.   23.               ... It would appear that the Caisse considered that its territory could be larger if it so directed ... the extent to which the investment income may be considered as being derived from economic mainstream activity ...

Hay cannot be considered a de jure director. Is the appellant a de facto director? ... Hay is not a de jure director, he can be considered a de facto director. ... Indeed, in American jurisprudence, a director has been considered as an officer. ...

., supra, the Federal Court of Appeal laid out certain matters which should be considered by this Court when hearing these appeals. ... Nevertheless, they considered it to be his business in fact, albeit not in law ... There were some factors that he considered just superficially and others about which he was mistaken. ...

He agreed that sale number four, which he considered was not "back land" and it had 146 feet of frontage. [16]     Parcel D would have a value of $3,881 based on the price per acre. ... At page 5 he considered that the highest and best use of the subject property would have been land banking for future unspecified development purposes. ... As earlier indicated on page 23 the appraiser considered this to be a building lot when it was not big enough for a building lot. ...

No. 1020, Judge Mogan, T.C.C., considered the status of workers supplying services to a non-profit organization funded mainly by the federal government. ... Canada, 2002 DTC 6853, the Federal Court of Appeal- post- Sagaz- considered the income tax appeal of a mechanical engineer specializing within the aerospace industry. ... Considering, however, the fact that the integration factor is to be considered from the perspective of the employee, it is clear that this integration was an incomplete one. ...

Some came back as hazardous and some were not considered to be hazardous. ... It was not considered to be hazardous then. [20] She was referred to the articles of incorporation of SPCMA, to the activities set out therein and its by-laws. She said that these were their objects and that there were no renegade activities considered that were not in the by-laws. ...

This was a Statement of Real Estate Rentals for the Appellant for the year 1996. [43]          In cross-examination the witness was asked what were the possible revenues that she considered in the care giving expense venture and she said that the agreement provided for $300 a month per child or $10 per day. [44]          With respect to the alleged rental losses, she was asked what sources of income were considered for Apartment No. 1 and she said that there was no rental income considered because it was used for looking after the children. ... If this were to be considered to be an adventure in the nature of trade, the real estate would have to become part of the inventory. ... The more closely a taxpayer's business or occupation is related to real estate transactions, the more likely it is that the income will be considered business income rather than capital gain. ...

Where serviced lots are acquired, site development is considered to begin at the earliest date the taxpayer starts to install further services to the lots or the day it starts to pour footings. ... The Court considered that the payment to be, in effect, a prepayment of city taxes. ... Therefore, the carrying charges and property taxes must be added to the cost of inventory under subsection 10(1.1). [112] With respect to all of these items which can be considered to be “soft costs”, the Court is satisfied that these were incurred during the “construction period”. ...

Although evidence of a contracting party’s subjective intention is not to be considered, exchanges can be considered as part of the factual background and circumstances. ... Since the Court considered and rejected that argument, the Fuel ITCs remained a common issue in both appeals and was fully resolved by the Decision. [28]         Admittedly, BCF presented that argument. ... In Sable Offshore Energy Inc. v Ameron International Corp., 2013 SCC 37, [2013] 2 S.C.R. 623 [Sable Offshore], the Supreme Court of Canada considered the purpose of settlement privilege. ...