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The question of when a debt is to be considered uncollectible is a matter of the taxpayer’s own judgment as a prudent businessman. ... Fisher described how this determination should be made: For the purposes of the /ncome Tux Act, therefore, a bad debt may be designated as the whole or a portion of a debt which the creditor, after having personally considered the relevant factors mentioned above in so far as they are applicable to each particular debt, honestly and reasonably determines to be uncollectable at the end ot the fiscal year when the determination is required to be made, notwithstanding that subsequent events may transpire under which the debt, or any portion of it, may in fact, be collected. ... In the same financial statements, we find this note: The parent company has undertaken to provide any additional working capital which the company may require in the next 12. [9] For these reasons, I do not think that the unpaid accounts owing by Flexi S.A. to Flexi, attributable to the unpaid accounts owing by Flexi U.K. to Flexi S.A., should have been considered to have become uncollectible. ...

This proposition is right when the appellants are considered qua employees but, is this the case when they are considered qua shareholders? ... If it were income from a property, it is interesting to read what is said in Ward's Tax Law and Planning, vol. 2 at chapter 43.1 [b] entitled "Timing of inclusion of property income": Although there is not a great deal of jurisprudence on the question, it is suggested that in light of the fact that sections 12(l)(a) and (b) are not applicable to income from property and that it was considered necessary to enact specific statutory rules requiring the accrual method to be used for interest income, income from property need not generally be computed on an accrual basis. ...

The meaning of the word "benefit" in paragraph 6(1)(a) was considered by the Supreme Court of Canada in Savage, supra. ... The Federal Court-Trial Division considered in Splane, supra, the receipt by a taxpayer from his employer of mortgage interest differential payments to reimburse him for increased mortgage interest payments which the taxpayer had to make following the purchase of a home in his new work location. ... This is a condition not dissimilar to that considered by Robinson J.A. in Phillips, supra, at page 389 (D.T.C. 6180):...it is also apparent that if an employee receives a payment on the condition that he or she continues to work for the employer... then that payment can hardly be said to have stemmed from considerations extraneous to the employment relationship. ...

As well he expressed the opinion that what he called the “chip handling system" in a mill should be considered as a single unit. ... Several cases dealing with the assessment of municipal or provincial taxes have considered the meaning of the terms “machinery” and "equipment". ... I say "part of the rocess” in that if a corporate taxpayer were involved in the preparation of fresh vegetables, for example, as was the case in Federal Farms Ltd., supra, and one of the steps in their preparation consisted of packaging the vegetables, then the packaging activity would be considered "processing" even though it did not change it.... ...

Subsection 118.4(1) of the Act read as follows: (1) For the purposes of sections 63, 118.2 and 118.3, (a) a person shall be considered to have a severe and prolonged impairment only if by reason thereof he is markedly restricted in his activities of daily living and the impairment has lasted or can reasonably be expected to last for a continuous period of at least 12 months; and (b) the Minister may obtain the advice of the Department of National Health and Welfare as to whether a person has a severe and prolonged impairment. ... Paragraph 118.4(1)(a) provides that for the purposes of the medical expens' nd the disability tax credits under sections 118.2 and 118.3, a person is considered to have a severe and prolonged impairment only if, by reason of such impairment, the person is markedly restricted in the activities of daily living and the impairment has lasted or can reasonably be expected to last for a continuous period of at least 12 months. ... In 1991 Parliament felt the need to incorporate in the Act what is meant and not meant by the phrase "activities of daily living": 118.4(1) For the purposes of subsection 6(16), sections 118.2 and 118.3 and this subsection, (a) an impairment is prolonged where it has lasted, or may reasonably be expected to last, for a continuous period of at least 12 months; (b) an individual’s ability to perform a basic activity of daily living is markedly restricted only where all or substantially all of the time, even with therapy and the use of appropriate devices and medication, the individual is blind or is unable (or requires an inordinate amount of time) to perform a basic activity of daily living; (c) a basic activity of daily living in relation to an individual means (i) perceiving, thinking and remembering, (ii) feeding and dressing oneself, (iii) speaking so as to be understood, in a quiet setting, by another person familiar with the individual, (iv) hearing so as to understand, in a quiet setting, another person familiar with the individual, (v) eliminating (bowel or bladder functions), or (vi) walking; and (d) for greater certainty, no other activity, including working, housekeeping or a social or recreational activity, shall be considered as a basic activity of daily living. ...

Furthermore, the appellant contends that the amounts and property received were repayments of a loan made to Roadrunner and as such were not to be considered as appropriations of funds from Roadrunner giving rise to a deemed dividend under subsection 84(2) of the Act. ... The appellant testified that he considered the transfer to the bank differently than a sale. ... In support of this proposition he relies upon Interpretation Bulletin IT-239R2 which states, at paragraph 4, A taxpayer who is required to honour a guarantee is considered to have acquired a debt at the time the guarantee is honoured equal to the amount of payment(s) made pursuant to the guarantee. ...

Subsections 56.1(1) and 60.1(1) deal with the question of when a payment to a third party will be considered to be "received" by a supported person. ... She may have had it prior to the order and even may be considered to have exercised it by agreement before the order. ... The Queen (1992), T.C.J., No. 634 the Court considered the capital argument. ...

That same day Olah forwarded an unsworn supplementary affidavit of documents and made particular reference to accounting records considered particularly relevant. ... In addition to Erlichman’s evidence I nave considered the affidavits and examinations of Stanley, Pomianowski and Siqueira. ... I have considered the criteria enumerated in the Rule and have concluded that a lump sum award is not warranted. ...

This estate had no assets which could be considered to be personal-use property, as defined in paragraph 54(f) of the Income Tax Act, R.S.C. 1952, c. 148 (am. ... Advisory legal services relating to the appellant's income tax returns may perhaps be considered as related to the appellant's income earning process if some evidence were produced to the effect that legal services were rendered for that purpose. However, on one hand, the account was not apportioned as such, and even if it had been, the reasonableness of the account would have to be considered. ...

Eng) received a letter from Rosales providing additional information which Rosales considered relevant with respect to the disallowance of West Coast business losses. 15. ... He responded and did provide additional material which was considered by the Minister. ... I am satisfied that the Minister examined the return with due dispatch, advised Rosales of the audit being performed with respect to West Coast, considered his submissions and then assessed the tax payable for the year. ...