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TCC

Stewart v. R., [1996] 1 CTC 2394 (Informal Procedure)

She stated that she considered whether the appellant was a person able to handle properly management and maintenance of the appliance. ... Canada), [1995] 1 C.T.C. 2927, considered the provisions of section 118.3 as it pertained to the taxpayer who had a colostomy and evacuated his bowel into a bag or pouch. ... Indeed, the language of Parliament is very clear and precisely defines what is and what is not to be considered a basic activity of daily living. ...
TCC

L.B. Farms Ltd. v. Minister of National Revenue, [1988] 1 CTC 2325, 88 DTC 1215

Dyck formed her opinion by looking backward from 1975 and considered as relevant to her conclusion plans which were then in place but which did not exist in 1971. ... All were considered solely for their agricultural capability, and indeed the comparable selected by Mr. ... The Ravis study forms part of the material considered by Mr. Helmers and was appended to his appraisal report. ...
TCC

Robert Peel v. Minister of National Revenue, [1987] 1 CTC 2373, 87 DTC 268

It is the settlement document dated October 24, 1983 (Exhibit A-1-5) which should be considered in determining this question. ... Continuation of Insurance: Disability — During periods of disability, an insured employee will be considered as still employed on a full-time basis, if the policyholder, acting on a basis precluding individual selection, continues that employee’s insurance. ... To what degree Constellation Life considered that a “liability” is not for me to examine — that just happens to be the word he used in the settlement. ...
TCC

Hazel M James, Robert E James v. Minister of National Revenue, [1985] 2 CTC 2001, 85 DTC 290

The sale of an eight-acre property for $7,688 per acre in November, 1972 was considered by Mr Keenleyside the best of the nine comparable sales, notwithstanding the same property was sold for $5,625 per acre in April 1972. ... Mr Michel considered seven comparable sales. Five of these comparables were used by Mr Keenleyside. ... Mr Michel's second comparable not considered by Mr Keenleyside was the sale of 6.39 acres, which included an old home and double garage, for $54,000 or $7,910 per acre, on May 24, 1972. ...
TCC

Perlman v. The Queen, 2011 DTC 1045 [at at 199], 2010 TCC 658

Hence, it was not considered at the objection and confirmation stage. ... Perlman and his wife are considered foreigners by Israel. His children have Canadian birth certificates and are both citizens of Canada and the US.     ... Amongst the facts to be considered is the original and continuing status of the person and the general mode of his life. ...
TCC

Manufacturers Life Insurance Co. v. The Queen, 2000 DTC 1600 (TCC)

The Queen, the Federal Court of Appeal considered the timing and method of computing certain foreign tax credits pursuant to section 126 of the Act and, in particular, the undefined word "paid" in the statutory provisions in issue. ... The Queen, both the Tax Court and the Federal Court of Appeal specifically considered the meaning of the defined term "reserves" in Part I.3 of the Act. ... Reserves, in this accounting sense, must be distinguished from provisions made in the accounts for expenses that are considered to have been already incurred but the amount of which may need to be estimated-- such as provisions for doubtful and accumulated depreciation. ...
TCC

Malenfant v. MNR, 92 DTC 2081, [1992] 2 CTC 2431 (TCC)

There is also the use of the television, which may be considered to be a service. ... Since a single hotel may offer a variety of accommodations, not all hotel guests can be considered transient. ... I am of the opinion that the services to be considered in a case of this nature are those included in the price of the room: the services for which the customer must pay a supplement cannot be considered as part of the rent for the room. ...
TCC

9178-3472 Québec inc. v. M.R.N., 2019 TCC 15

Mbaye, it is clear that the payor considered all workers to be self-employed. ... Among the others, some considered themselves to be employees, and others considered themselves to be self-employed. [89]   The witness says that the majority of workers agreed to be self-employed not by choice but because they had to work. ... In that case, delivery people were considered self-employed. They all had a written contract. ...
TCC

Industries S.L.M. Inc. v. Minister of National Revenue, [1996] 2 CTC 2572, 96 DTC 3215

Determinate and limited succession of like things forming a whole, or considered as such.... ... A number of authors have considered the meaning of the expression “series of transactions” [12] in the context of the new section 245. ... In other words, the point to be determined is whether, under the circumstances, S.L.M. can reasonably be considered to have artificially or unduly created a loss? ...
TCC

Sears v. The Queen, 2009 DTC 1370, 2009 TCC 344 (Informal Procedure)

The fact remains, though, that each case must be considered on its own facts, by weighing and balancing all of the relevant factors. ... Minister of National Revenue, [1964] S.C.R. 209, [1946] C.T.C. 51, 2 DTC 812 (S.C.C.), the meaning of the words "ordinarily resident" in paragraph 9(a) of the Income War Tax Act was considered. ... No. 158 (QL), Justice Campbell considered the appeal of a pipe welder who kept a home in Nova Scotia but travelled on four different occasions during the year at issue in order to obtain work. ...

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