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Daoust, the bank considered him as the true owner beginning on April 15, 1982, and all the rest was only the settlement of an existing situation. ... Daoust become and be considered the owner of the said business capital following the date on the promise to sell mentioned above, i.e. ...

The respondent's appraiser also considered a V-Day income approach to value, but the rental or income produced resulted in a lower value than the direct sales comparison approach and so was discarded. ... The third method was not even considered by either appraiser, while the second was only briefly touched on by the respondent's appraiser and discarded. ...

Vouchers in the amount of $500.70 were not accepted, because they were considered inadequate for entertainment purposes. ... Gilling, [1990] 1 C.T.C. 392; 90 D.T.C. 6274, at 398 (D.T.C. 6278), which assert that even if it is not explicitly stated in the contract that one must pay one's own expenses, this can be considered as implicit, given the terms and conditions of the job. ...

Accordingly, my client's averaging period consisting of four of the six immediately preceding years should be considered correct within the interpretation of 119(4). ... I can only conclude that the earlier reference to the year 1977 was related in some way to an effort on the part of the appellant to utilize the years he considered most advantageous to him, not unlike the instant case. ...

The improvements were considered to have been in average condition at the date of valuation. ... Blaauw specifically considered, as an added factor, that the subject property at the date of valuation consisted of a house and a garage and that it had been improved to permit its use as a revenueproducing rental property. ...

In support of the motion counsel for the respondent also argued that there had been no notice from the appellant that an application under Rule 7 was being considered. ... I have considered Rules 6, 7 and 8, counsel's submissions and the reasons of Taylor, T.C.J. in Cotroneo v. ...

Dealing with the matter of the transaction being at arm's length it is difficult to comprehend that when a person who is a shareholder, director and president of a company receives shares, even though he abstained from voting on the issuance to him of the shares, can be considered to be dealing at arm's length. ... Thus they could not be said to be dealing at arm's length when the true substance of the transaction was considered. ...

No question was raised by the Minister with regard to the matter of the expenses involved, or whether some of these might more appropriately be considered capital rather than current costs. ... This situation might well be one of the few in which a legitimate claim for "start-up costs" should have been considered. ...

I therefore respectively ask, that the sum of $4,215.00 be considered as a legitimate deduction from my 1983 income. ... Obviously, if Revenue Canada, considered that Mr. Floro had been an employee of Bobsien in 1983, and that by not properly deducting income tax, and preparing a T-4 slip, Bobsien was in error, then redress for that situation against Bobsien was available under the Act. ...

As noted above, the view of counsel for the appellant was that the break down of selling price (supra) (per Exhibit A-3) should not be considered as an agreement between the parties. But even if so considered, the case law did not require the Court to accept it as a reasonable allocation, and counsel quoted from the Federal Court of Appeal decision in Golden v. ...