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The appellant offered his assistance and a number of proposals were considered. ... In the initial stages of their search several fairly substantial businesses were considered. ... The Court notes that similar facts were considered by the Tax Court of Canada, in Ena M. ...

Recently the Federal Court of Appeal has considered anew in Tonn v. R [2], the relevancy of reasonable expectation of profit to the deductibility of losses. ... Beecroft considered how much money they would have to earn from the North Shore so as to realize a profit. ... The fact that the partners considered the property their principal residence creates the personal element as “the dominant, motivating force” in acquisition of the property. ...

The Minister of National Revenue (“Minister”) considered these profits to be business income. ... The appellants considered the profit realized on the fourteenth lot to be business income since they had held it for a period of only six months. ... To my mind, it is not without significance that that course was the only alternative course considered and that it was decided upon as the only thing left to do. ...

.), the Federal Court of Appeal considered the application of section 15 of the Charter to section 118 of the Act. In doing so, the Court considered the groups distinguished by this section. ... T.D.), Madam Justice Tremblay-Lamer of the Federal Court- Trial Division said at [para28-29]: [para28] At this point, the specific characteristics of the Income Tax Act should be considered. ...

  [47]         At the three valuation dates being considered, Northside had advances to Brimmond Farms Inc. ... An advance of $71,487 to a Director in 2001 was also considered a redundant asset ... Hawkins considered that the net realizable value of the redundant assets and related liabilities are nil ...

(m)       Consequently, the Minister considered both amounts appropriations of funds by the Appellant, and added them in computing his income.               ... She considered the explanations that the parties concerned submitted to her and verified the information provided to check whether it made sense and, above all, was plausible ... The results that she obtained were not consistent with the appellants' contentions, and thus, the explanations that were provided could not be considered plausible ...

Conversely, as I will discuss subsequently, the College cannot be considered a denomination. ... The meaning to be ascribed to the term congregation was considered in Barnes v. ... The final question to be determined is whether the College can be considered a religious order. ...

All were supervised by the appellant herself and her common-law husband. [14]     For both of the taxation years at issue, the appellant was considered by the province of New Brunswick to be a farmer for the purposes of the provincial sales tax farm exemption and has been so considered since 1979. ... Given the total acreage being used in comparison to other farms in New Brunswick, the appellant's farm is considered a large farm. ... For the purposes of section 31, everyone's involvement with the farm should be considered, and not just the appellant's. ...

Those facts are as follows: (a) Eidi Ghnim is the appellant’s mother; (b) Eidi Ghnim was born in 1917; (c) Eidi Ghnim is considered totally dependent on the appellant by the government pursuant to an immigrant sponsorship contract; (d) Eidi Ghnim has no mental or physical infirmities; (e) for the 1995 taxation year, the appellant is not entitled to the dependant tax credit for his mother, Eidi Ghnim, because she has no mental or physical infirmities. [3] When he testified, the appellant stated that the first part of subparagraph (c) should have been worded as follows: (c) Eidi Ghnim is considered totally dependent.... [4] During his testimony, he clearly stated that he was not challenging the constitutionality of the Income Tax Act (“the Act ”) or relying on the provisions of the Canadian Charter of Rights and Freedoms. [5] He basically testified that his 80-year-old mother could not fit in because of her language, age and education. [6] He said that since he signed a 10-year immigrant sponsorship contract, his mother was totally dependent on him pursuant to that contract. [7] He explained that he neither understood nor accepted the fact that there was no consistency between his contractual obligations and his tax liabilities. [8] He also stated that he had made the Department of Finance aware of his complaint. ...

Clients' needs would have to be considered and recommendations made for improving the effectiveness of the existing advertising and proposed improvements. [7]            The Appellant made an arrangement with his wife to perform preparatory services on his clients' lists (provided by his employer) and to make recommendations to improve those clients' listings for the Appellant to present on his calls on such clients. ... This assistance could save the Appellant much valuable time and improve his ability to increase new sales commissions. [8]            It was vigorously advanced by the Appellant that his wife should be considered as an independent contractor as she was hired under a contract for services and thus any monies paid to her could be deducted from his commission earnings. ...