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Such a reason at best has, in my opinion, very little weight or validity by itself and I think has even less when considered in the light of the legal obligation upon the person making the return to be accurate and truthful on pain of severe penalties both for untruthfulness and for omissions. ...

In addition, she argues that one-half of the interest earned on the amount in 1987 was declared by the appellant on his 1987 income tax return, indicating that he considered it to be his own. ...

This would indicate that the Court felt that all factors should be considered as a group and no one factor should determine the existence of a source of income. ...

The second point at issue is whether the penalties and interest imposed under the Income Tax Act for failure to remit on time the amounts deducted at source may be considered as an expenditure of a current nature for the purposes of paragraphs 18(l)(a), 20(1)(c) and subsections 127(5), 127(9) and paragraph 37(1)(a) of the Act. ...

Thus, an item such as a typewriter which might be considered a tool, is properly regarded as machinery and is placed in class 8. ...

In considering the application the Farm Credit Corporation considered that the property had a value of $540,000. ...

However, if the items set out below may be considered to be valuable assets, we might then think that the $99,247 owing did not become uncollectible until later. ...

While the appellant did not specifically raise the issue, I have considered whether the appellant's rights under section 15(1) of the Charter were contravened because the appellant spoke of "unfair treatment". ...

In this regard the Minister relied on the words of exception found in paragraph 81 (1)(a) of the Act which provision reads: 81(1) There shall not be included in computing the income of a taxpayer for a taxation year, (a) an amount that is declared to be exempt from income tax by any other enactment of the Parliament of Canada, other than an amount received or receivable by an individual that is exempt by virtue of a provision contained in a tax convention or agreement with another country that has the force of law in Canada; The Minister considered that the deduction in the computation of taxable income authorized by paragraph 110(1)(f) of the Act constituted sufficient compliance with the treaty. ...

Moreover, the explanation about the frustrations of a mutual drive is of limited value when considered against the short period of time the taxpayer apparently offered the property for rent. ...