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Full time non paid work Founding member Burnaby Mountain Preservation Society which saw 880 acres of land returned from SFU to Burnaby as park space The Minister considered the value of the golf pass as a retiring allowance pursuant to paragraph 56(I (a) of the Income Tax Act (the "Act") or, in the alternative, the Minister submits that the Appellant received the amounts as employment income pursuant to paragraph 6(1)(a) and subsection 6(3) of the Act. sociation of B.C. ... In order for the benefit amount to be considered a “retiring allowance”, the Appellant must have received it in the year in lieu of payment of or in satisfaction of a retiring allowance. ...

The issues in this appeal are: a) whether the Appellant is entitled to a deduction for moving expenses in relation to his trip to British Columbia in 1994; b) whether the Minister of National Revenue (the “Minister”) properly considered social assistance payments made to the Appellant’s spouse in reassessing the Appellant’s claim for the spousal amount. ... In reassessing the Appellant the Minister made the following assumptions of facts which the Appellant admitted or denied: a) the Appellant went to British Columbia during the 1994 taxation year in search of employment; (denied) (b) while in British Columbia during the 1994 taxation year, the Appellant worked for employers in North Vancouver, Surrey, Abbotsford and Coquitlam; (admitted) (c) the Appellant returned to Newfoundland prior to the end of 1994; (admitted) (d) on his 1994 income tax return, the Appellant indicated that his place of residence of December 31, 1994, was Newfoundland: (admitted) (e) the Appellant’s spouse continued to reside in Newfoundland and her child tax credit payments continued to be directed to a Newfoundland address; (admitted) (f) the Appellant’s third child was born in Newfoundland on December 21, 1994; (admitted as amended) (g) the Appellant did not provide any documentation in support of his claim that his family accompanied him to British Columbia; (denied) (h) the Appellant did not move to British Columbia as a result of a change in employment nor did he establish his ordinary residence in British Columbia; (denied) (1) the Appellant is not entitled to claim moving expenses in relation to his trip to British Columbia; (denied) (j) the Appellant’s spouse received social assistance payments of $4,320 in Newfoundland during 1994; (ignored) (k) the social assistance payments were considered part of the net income of the Appellant’s spouse; for purposes of determining the Appellant’s entitlement to the spousal amount. ...

He considered a number of possibilities, including a boat charter business, and the manufacture of custom canes for the disabled. ... Prince, in his evidence, attributed this to the fact that he could not recruit people to do either the knitting or the selling for him at what he considered to be suitable rates of pay. ...

She contended that the Borck decision (supra) confirmed that the accountant's fee should not be considered a disbursement. ... Can the accountant's fees be considered an “essential” disbursement, or are they fees for the type of services normally provided by counsel simply recharacterized as a disbursement? ...

.… Deputy Judge Smith also reviewed the case law which has dealt with this issue and held that the following criteria should be considered when dealing with the question of when to grant an extension of time to file an appeal: 1. the Applicant must show a bona fide intention to appeal when he had the right to appeal; 2. that his failure to appeal within the delay was the result of a special circumstance which serves to excuse or justify such failure; and, 3. it must at least be arguable that the judgment appealed from is wrong. ... This question was also considered by the Federal Court of Appeal in Tyler v. ...

When a child is emancipated and leave the custody of the spouse, the problem addressed by Parliament in allowing the deduction of amounts paid for the benefit of the child ceases to exist: from that point on, the former spouse no longer has a duty of care deriving from his or her right of custody, and the support can no longer be considered to be owing or paid on account of that duty. ... The appellant’s former spouse was also not called upon to testify because the Court was informed that the acrimony between her and the appellant is such that he considered calling her as a witness on his behalf would be impracticable. ...

I agree that in defining whether an activity constitutes SR&ED for the purposes of the Act it is not to be considered in its constituent parts, but as a whole. Testing would not normally be considered as an eligible SR&ED activity. ... Should the component parts when considered alone fail to meet the requirements of Regulation 2900, then neither of subsections 37(1) or (2) would apply as the activities would not constitute SR&ED. ...

[Emphasis added] There is no logical reason why this approach cannot be considered with respect to paragraph 8(1)(f). ... The existence of a personal interest in similar circumstances was considered by Rip J. in Matt Harris & Son Ltd. v. ... Counsel for the Appellant submitted that neither the decision nor the settlement should be considered in these appeals. ...

The distinction between income from a business and income from property was considered in Canadian Marconi Company v. ... On first reflection this sort of income could realistically be considered either business income or property income. ... The Queen, [9] Judge Bonner considered whether the taxpayer was in the business of lending money for purposes of paragraph 20(1)(p). ...

Drilling Ltd., 76 DTC 6028, in which Judge Urie considered in obiter the question of when a corporation begins operating a business. [31]     In M.P. ... The Court considered the fact that the company was already in existence and had done everything that any new business normally had to do to market its merchandise. ... The architect Cayer moreover was not paid by the Corporation but by the appellant Boulanger, who considered the payment as an advance to the Corporation. ...