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No. 46, the Supreme Court of Canada considered the test of the reasonable expectation of profit; we need only reproduce here the Court's summary, found at paragraphs 60 and 61: 60.        ... Thus, where the nature of a taxpayer's venture contains elements which suggest that it could be considered a hobby or other personal pursuit, but the venture is undertaken in a sufficiently commercial manner, the venture will be considered a source of income for the purposes of the Act. 53.        ... We would also emphasize that although the reasonable expectation of profit is a factor to be considered at this stage, it is not the only factor, nor is it conclusive. ...

The Department therefore considered that the appellant corporation earned additional income in the amount of $41, 907, $10,880, $88,018 and $61,289 for the fiscal years ending respectively on April 30, 1994, 1995, 1996 and 1997;   7.         ...   [16]     Lucie Pelletier also stated that the restaurant and bar was a very good business; she had even considered purchasing it during the months preceding the bankruptcy for approximately $200,000, which she had in cash in various safety deposit boxes and at her home ...   [35]     Lucie Pelletier was employed by a restaurant she considered so interesting that she said that a few months before the bankruptcy she was prepared to invest approximately $200,000 to purchase it. ...

Might be considered an employer‑employee relationship Might be considered self‑employment or simply uninsurable Workplace The worker works at a place owned or leased by the employer. ...   [37]     A case similar to the instant ones was considered by this Court in Lebouthillier v. ... No. 319:               The Court considered in detail the evidence put before it. ...

O'Connor was considered to be a high-risk offender in need of 24-hour supervision. [4]            Mr. ... The most that can be said is that control will no doubt always have to be considered, although it can no longer be regarded as the sole determining factor; and that factors, which may be of importance, are such matters as whether the man performing the services provides his own equipment, whether he hires his own helpers, what degree of financial risk he takes, what degree of responsibility for investment and management he has, and whether and how far he has an opportunity of profiting from sound management in the performance of his task. ... The overall evidence must be considered taking into account those of the tests which may be applicable and giving to all the evidence the weight which the circumstances may dictate. ...

To formulate a decision then, the overall evidence must be considered taking into account those of the tests which may be applicable and giving to all the evidence the weight which the circumstances may dictate. ... However, that is not considered profit in the sense that the word is used in this situation. ... " and that question has to be considered from the point of view of the Worker. ...

Ishak's gross monthly salary was roughly $10,000 and he received three $5,000 advances — two in February and one in March 1993 — but they were considered by Mr. ... Ishak still considered that he had incurred more out-of-pocket expenses than the amount of his share of "loans receivable from directors". [14]          In the end, no legal action was brought. ... Therefore, those expenses could be considered to have been paid by being set off against a portion of the advances. ...

Respondent's counsel raised the argument, for example, that the maintenance and repair of roads within the City's boundaries are generally considered to be part of standard municipal services. ... And, because they are made free of charge, that department concludes that the supplies are not considered to be made in the course of a commercial activity. [24]          The fact that the work is undertaken pursuant to a statutory obligation does not disqualify the work from the character of a commercial activity, so long as the person who undertook the work did not make exempt supplies in carrying on the undertaking. ... The trial judge, in finding a direct link between the supply made by the non-profit organization and the grant, considered the plans between the municipality and the non-profit organization early in the planning stages of the pool's construction. ...

It is considered that a literary work such as a novel, poem, short story or any non-fictional prose composition that is written for general sale or syndicated distribution would normally have a greater profit potential than a work undertaken for restricted distribution. 6.              ... All relevant criteria are considered together in making a determination and the taxpayer's failure to meet any one particular factor will not in itself preclude the taxpayer's artistic or literary activities from qualifying as a business. 7.              ... However, in order to have this "reasonable expectation of profit" the artistic or literary endeavours, as the case may be, of the artist or writer must be carried on in a manner such that, based on the criteria in 5 above, they may be considered for income tax purposes to be the carrying on of a business rather than, for example, a hobby. [8]            Whoever wrote the above demonstrated considerable sensitivity to the nature of artistic endeavour and a recognition of the validity of the aphorism ars longa vita brevis. ...

That at that time, that is, when the Act came into force on January 1, 1991, the appellant and Les Supermarchés GP Inc. were considered to be "closely related corporations" within the meaning of subparagraph 128(1)(a)(vi) of the Act;   3.         ... According to the Supreme Court:   [D]iscretion cannot be considered in the absence of an examination of the legislative objectives, and the important question is whether the presence of such discretion can be rationally tied to those objectives. ... I have already considered this Court's lack of jurisdiction to review the exercise of the Minister's discretion in Gretillat v. ...

His background and his other land dealings in those years are relevant facts to be considered in determining the Appellant's intention with respect to the two properties in issue. ... The Appellant was familiar with one such residence situated at 102 Water Street, considered it to be worth saving and brought it to White's attention. ... In reaching this conclusion, I have reviewed the documents filed as exhibits and the testimony of the Appellant and White in light of other proven facts and have considered such matters as, inter alia, the time-frame involved and White's financial condition. ...