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While I have no doubt that the appellant expended all or most of the claimed expenses on matters which she considered related to her employment, and that such expenses were beneficial to her employer, the Income Tax Act, R.S.C. 1952, c. 148 (am. ...

It is irrelevant whether the amounts at issue are considered as income from employment or only income from a source. ...

It had all the information and argument that it considered necessary and it also had the jurisdiction and power to make the order it did respecting costs. ...

However, he considered Mr. Descent's suggestion as being a possible solution and at that point suggested bringing in his wife as his partner. ... Had DEL sold its Kingstonbranch to a third party, that sale of part of its business presumably would not have been considered a reorganization. ... Rather, I find that this transaction may reasonably be considered to have been arranged primarily for bona fide purposes other than to obtain a tax benefit. 2.       ...

Further, paragraphs 6(1)(f) and 56(1)(a) of the Act were considered. [5]            Exhibit A-3 was admitted by consent, which was a letter dated December 2, 1999. ... Worker's Compensation payments are not taxable and these payments were considered to be made in lieu of Worker's Compensation and consequently were non-taxable. He considered his own payments to be of the same type. [14]          He wrote to Mr. ...

Huppé explained that the appellants were considered limited partners because the risk associated with their investment was limited. [51]     The risk was limited in the sense that a partner could lose only one half of the investment. The redemption offer as well was a benefit since the Partnership no longer had any assets when the research contract was awarded. [52]     They could have been considered sleeping partners. ... I could have considered that request. In any event, the Minister's expert had considered the two existing documents pertaining to the planned research. [80]     The same appellant also objected to the lengthy period of time that had elapsed between the year in question and the year in which his appeal was heard. ...

However, the Court considered the profit from the sale of a certain number of buildings as a capital gain. ... Consequently, the other factors must be considered. 4.03.4 Counsel for the appellant alleged that the appellant could have been considered an investment company during the years in issue. ... It is true that these reasons, together with other circumstances, have often been considered sufficient by the courts to find that there was a capital gain. ...

Indeed, both witnesses considered that the appellant’s shares were held jointly by the couple. ... If the witnesses really considered that the couple’s assets were held jointly rather than individually, why was it necessary to acknowledge Ms. ... The words “unless the transaction may reasonably be considered” in subsection 245(3) of the ITA demonstrate that this test is not only subjective but also partly objective. (53) In this instance, the sale of shares by the appellant to his spouse was definitely a tax-motivated transaction. ...

These circumstances must be taken into account, but must be considered against an objective “reasonably prudent person” standard. ... By contrast, facts external to the director but which are part of the context in which the director acts are considered. ... Accordingly, I have considered whether this approach is appropriate or whether the Appellant’s mental health is otherwise relevant in determining the Appellant’s potential liability as a director for the failed remittances. [35] Decisions of this Court have considered a director’s mental health as relevant to the due diligence defence. ...

Her conclusion was that since a retiring allowance is not considered a "salary" or “wages” for the purpose of the Act, therefore the provisions of paragraph 8(1)(b) are not applicable and the appellant may not deduct his legal expenses in computing his income for the taxation year under appeal. ... In arriving at the quantum of the award, the Court took into account the salary of the appellant and applied it to a notional period of employment which it considered should have been given to the appellant prior to the termination of his employment. ...