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The appellant was entitled to no notional credit since the sale was in fact an accommodation sale which the auditor considered as such. ... This is due to the fact that, in the working paper, we considered the agreements in issue as accommodation agreements. ... Other, Non-Taxable Deposits The amount of the other, non-taxable deposits considered by the auditor is $71,304.80. ...

In my view, this tax advantage should not be considered in determining whether Dr. ... I believe Judge Brulé rightly considered the costs relating to the acquisition of property as irrelevant to the determination of its fair market value. However, nowhere did he state that the purchase price paid by the taxpayer should not be considered in determining fair market value. ...

She answered that, if one referred to the letter from the department dated February 8, 1990, it was more because this question had not been considered important. ... To the question as to whether the appellant had considered the tax consequences at the time this document was prepared, Mr. ... The substance of the transactions, it was submitted, was considered only in cases of tax avoidance. ...

If the individual parts are so intertwined or interconnected to the overall arrangement that they cannot be realistically separated, then they will be considered to be part of a single whole rather than regarded as separate and distinct parts or entities. [15] [21] In Hurd Dentistry, one of the issues considered by Justice Campbell was whether Dr. ... McCarty, [19] which considered the question of whether the transfer of dentures and other prosthetic devices from a dentist to his patients constituted a sale for the purposes of the Alabama Sales Tax Act (the “ASTA”), or was incidental to the professional treatment rendered by the dentist. ... In deciding that issue, Justice Bédard considered two questions: a) Was a filling or crown provided by Dr. ...

He pointed to the level of trading activity within his own RRSP as evidence that he carried on such a business outside his RRSP. [26] [32] In concluding that the appellant’s loss was on capital account, this Court held that the level of trading activity within an RRSP cannot be considered in determining whether a taxpayer was in the business of trading outside his RRSP. ... When considered in light of the overall structure of the TFSA rules, the purpose of the exception in subsection 146.2(6) — which makes income from the carrying on of one or more businesses by a TFSA taxable — is to ensure that the tax exemption is restricted to the passive holding of qualified investments. ... There is no indication that the Court considered paragraph 146(4)(b) — which expressly contemplates an RRSP trust carrying on business trading in qualified investments — and the Crown did not bring that provision to the Court’s attention. ...

Neither BDI nor Peninsula was looking to make money on the Tremont Apartments project since they considered it a cost of developing the condominium project. 8 Mr. ... At one time he considered that it may be necessary to “roll in a nominal asset to achieve this goal”. ... Gouveia stated that “maybe for a fleeting moment” the Canadians considered retaining the condominium development. ...

For example, a specific admixture may be considered at the start of the project to meet a certain standard. ... A fine‑tuning activity will not be considered an SR&ED activity if its goal is not to advance technological knowledge. ... The lasting improvement of a property is normally considered to entail a capital expenditure. ...

That expense was disallowed only because the Crown considered Dynamic to be carrying on a personal services business. ... The expression “more than” is used over 200 times in the Act and has been considered by this Court on several occasions. ... I am of the view that his comments in regard to part-time employees can be considered obiter ...

.), referred to by the appellant, the court listed some factors considered to be material in determining the question of fiscal residence, at page 5163:  ... ... Finally, the Boston case was considered but not followed in the McFadyen case, which was affirmed by the Federal Court of Appeal ...   [47]          Regarding the beginning of the relevant period of the appeal, the beginning of 2007, it must be considered that a reasonable person would be careful. ...

It should be noted that, under subsection 56.1(4) of the Act, support is considered a child support amount if it is not identified as being solely for the support of a recipient who is a former spouse ...   [42]         Justice Favreau properly considered and reviewed the case law on the issue of discretion as to the use of the support amount. ... Conclusion   [44]         Having considered all of the evidence as well as the submissions before me, I have made the following findings:   a.                  ...