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  [7]      I accept her evidence that she was considered by Walden as in full‑time attendance. ... The Queen, [2] Bowie J considered the meaning of full‑time attendance. ...

By notice of confirmation dated March 20, 1990, the Minister of National Revenue confirmed the part VIII tax assessment for the 1985 taxation year on the following basis: The Minister of National Revenue has considered the facts and reasons set forth in your notice(s) of objection and hereby confirms that the assessment(s) has (have) been made in accordance with the provisions of the Income Tax Act for the following reasons: Expenditures of $294,153 incurred in the computer aided learning research project do not constitute scientific research and experimental development expenditures within the meaning of paragraph 37(1)(a) and Regulation 2900(1)(f) of the Income Tax Act. ... Some of the factors considered relevant in deciding whether the project (development of the prototype of a machine) in Sass Manufacturing Ltd., supra, fell within the definition of scientific research and experimental development were: the elements of scientific uncertainty in the activity, technology advances, uniqueness of research, experimental (systematic) approach, scientific experience of the staff, and the nature of the data collected. ...

Ballance testified that he had signed the demand loan agreement sometime between the first and the middle of July 2002. [9]      I have carefully considered all of the evidence that was before me plus the legal authorities that were provided by counsel. ... Ballance on July 5, 2002, and that the money was lent back by each of them to the Appellant on an interest-free demand loan basis. [10]     In reaching my conclusion I have considered a number of authorities including, in particular, the decision of Chief Justice McLachlin in Shell Canada Limited v. ...

However he found that this would have been disruptive to the children and that he considered he made payment by directly transferring his equity in the assets in question. ... Surely therefore the transfer must be considered as a form of payment. ...

Other provisions were that the loan or any part thereof could be repaid on five days' notice, the appellant was required to maintain a margin of 110 per cent of the amount borrowed or the loan would be considered in default. ... Any of the taxpayer's normal trading activities resulting in profit or loss from foreign currency dealings would be considered as adventures in nature of trade and regarded as being an income account. ...

He said he considered the funds in Holdco and Ottawa as "the same pot”. ... The Federal Court-Trial Division considered the appeal of Tick v. M.N.R., [1972] C.T.C. 137, 72 D.T.C. 6135. ...

While the factors I have just described [8] tend to point in the direction of an investment, there are three other factors that need to be considered. ... In particular, there is no information as to what may or may not have changed in 2005 as compared to prior years. [11]   [27]          This leads to the third and final additional factor that needs to be considered. ...

(denied) Only the occupant of 2219, whose unit needed less significant repairs, remained in the unit throughout the entire renovation period; (admitted)   (i)                   The cost of the renovations was 1.75 times higher than the purchase price for the building; (no knowledge)   (j)                  The amounts of $44,899 for 2004, $41,885 for 2005, and $85,952 for 2006 claimed by the appellant under the "maintenance and repairs" item were disallowed because they were capital expenditures; (admitted)   (k)                The consulting engineer's, architect's and notary's fees concerning the loan for renovations, totalling $8,922 for 2004, were also considered to be capital expenditures; (admitted)   (l)                   The auditor also reconciled the amortization schedule for each building and granted the following deductions to the appellant as capital cost allowance: (admitted)              2004         2005         2006 2219-2225 Bardy $3,809 $2,543 $9,556 669 4th Avenue $0 $1,103 $2,161 Total              $3,809 $3,646 $11,717   [5]               Paragraph 6(f) of the Reply to the Notice of Appeal was denied because the problems with the building were noticed not when it was purchased but rather within the year following the purchase. ... Such expenditures cannot in any way be considered as being for minor repairs or regular maintenance. ...

Jones was told by the auditor that her daughter was considered old enough to stay home alone after school and that child care was not needed for that portion of the day. ... The judge considered all the circumstances and concluded that the taxpayer's purpose in enrolling the child in the school was for child care and that the educational aspect was incidental. [17]     The Crown in Bailey argued that the service provided by the private school was essentially education and as such the fees were subject to the exclusion for "education" in the definition of "child care expense. ...

The Appellant was more interested in an investment and losses were not a factor that he considered. ... No. 775, in which a similar set of facts as those in the appeal at bar were considered whereby a property was purchased in Florida and involved the same company, Port Charlotte Home Builders R.D. ...