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Goodman could not reasonably and properly be considered as revenues and therefore could not be the subject of "matching". ... He also considered if, in computing the appellant's income, whether expensing the entire amounts to the year of payment or whether over the terms of the leases was preferable. The third issue considered was whether TIPs can be considered to be period costs or "running expenses". ...

The proposition that financial difficulties of the taxpayer which forces a sale is a factor to be considered. ... An unsolicited attractive offer is a factor to be considered: S. & S. ... Involvement in real estate through career should be considered: Davidson v. ...

The respondent considered the profit to be an income from business while the appellant argued that it was a capital gain. ... De Champlain stated that he considered the “case” somewhat difficult. ... A first proposal to M.H.T., which was considered unacceptable, may have been made by Mr. ...

The alternative of the employees taking the actual number of lieu days missed was never considered, and under the circumstances, it should not be considered by this Board as a comparable substitute. ... The arbitrator noted that the alternative of giving Vincent a day off for each rest day missed was neither advanced nor considered. ... Whether this administrative stance is legally correct is not a matter which need be considered at this time. ...

Property used more than 50% of the time for the purpose of gaining or producing gross revenue that is rent, royalty or leasing revenue is considered to be used principally for that purpose. ... Counsel for the respondent referred the Court to several decisions in which the term “passenger" was considered. Most of these decisions related to sections of provincial Vehicles Acts and must be considered with care. ...

Graham stressed that a purchase of a list of accounts from Shell did not eliminate Shell, nor could a purchase of this nature be considered as buying the business of Shell. ... No reason has been advanced for the appellant to have considered or apprehended that the Ingersoll operation would have been dealt with differently. I have considered the decision of Halliday Fuels v. M.N.R., supra, which is a decision of the then Tax Appeal Board in 1960. ...

Counsel agreed that the amount at issue is to be considered as being $8,517 received by the appellant in the 1977 taxation year. ... Atkins considered the whole amount as damages for breach of contract and, as such, contended that it was non-taxable. ... Mr Lefebvre’s last contention that the amount received by the taxpayer was a taxable capital gain cannot, in our opinion, be considered. ...

He further considered that the amount claimed was not reasonable in the circumstances and could not be deducted pursuant to s. 67 of the Act. ... The appellant considered these salary and education expenses paid during those years as expenses of operating his business. ... Furthermore, if the expense is considered from a practical and commercial standpoint, it is unlikely that an employer would have incurred such expense if he had not regarded it as an essential element in the pursuit of profits for his business. ...

When he was asked in cross- examination if it was because dividends or salaries would be paid, the witness answered "no", only the cash flow had to be considered. ... M.N.R., [1993] 2 C.T.C. 123, 93 D.T.C. 5362 and more specifically at pages 125-26 (D.T.C. 5364-65): The Trial Division found that the loan to the respondent, even though made after the acquisition of the house, ought to be considered to have been made to enable or assist him to purchase that house since the loan was made pursuant to a commitment given by the lender to the respondent prior to the acquisition of the house. ...

  [20]         The Respondent’s counsel alleged that an individual cannot be considered to be an educational institution for the purpose of subparagraph 118.5(1)(a)(i) of the Act and he distinguished the Tarkowski decision by pointing out that the Mississauga School of Music was a school that was teaching the music courses and that Mateusz Tarkowski was tutored at the school by a teacher ...   [22]         I do not think that one‑hour piano lesson per week is sufficient for the Appellant’s son to be considered as being enrolled at an university, college or other educational institution providing courses at a post‑secondary level ...