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I depend on the service provided by Manpower and would hope that the service can be considered dependable. ...

The expenses must be considered as personal and not deductible. 5. Conclusion The appeal is dismissed in accordance with the above reasons for judgment. ...

That reorganization was considered to be a desirable preliminary to a proposed public offering of Imaginaction shares. ...

The length of time that is considered “reasonable” depends on the individual and the circusmstances of each case, but that is not the issue before the Court in this matter. ...

The following criteria shoud be considered: the profit and loss experience in past years, the taxpayer’s training, the taxpayer’s intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...

I might also refer to the Reasons of Mr Justice Rand where he said, at 713: It is, I think, misleading to convert a transaction of this sort into what is considered to be its equivalent and then to attribute to it special incidents that belong to the latter. ...

However, the broad question arises: — Did the appellants go to such extremes in arranging their affairs that they caused dividends to be paid to their wives which, pursuant to section 56(2) of the Income Tax Act, must be considered as taxable to the appellants as if they themselves had received the dividends? ...

Part IV Additional Jurisprudence Cited and Considered FCTD — Kasper v The Queen, [1982] CTC 178; 82 DTC 6148; Plante v The Queen, [1983] CTC 341; 83 DTC 5378; Graham v The Queen, [1983] CTC 370; 83 DTC 5399. ...

The Respondent submits that as the Appellant and his wife had no reasonable expectation of profit in renting out the condominium in the 1980 taxation year, no amount may be deducted in respect of the operation thereof as no amount can be considered an outlay for the purpose of gaining or producing income from a business or property within the meaning of paragraph 18(l)(a) of the Income Tax Act. ...

I find that the Appellant’s legal obligation to purchase the condominium was entered into in 1988 and that is the relevant year to be considered in determining whether the Appellant had a reasonable expection of profit. ...