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Severinov filed this appeal before the CRA had considered the notice of objection. ... Severinov may have contributed to this because he filed an appeal before his objection was considered. ...

Savage. [4] In that case the Supreme Court of Canada considered the taxability of a payment of $300 made by an employer to an employee as a reward for the successful completion of certain business related courses. ... Reimbursement for out of pocket expenses incurred as a result of a move, explains NoËl J., cannot be considered a benefit because it adds nothing of value to the recipient’s economic situation. ...

  [25]          Further, Justice Bowman held that, the Appellant was attending full-time as he was considered a full-time student by the institution and did 22 to 36 hours of course work per week. ... The Queen, 2006 TCC 145, 2006 D.T.C. 2685, Justice Woods held that, for online educational programs to be considered full-time, they need only require the attention of the student on a “full-time” basis. ...

It seems to me that all of the expenditures relating to the investigation of opportunities must be considered on the same footing. ... The Court held at pages 837-38 (D.T.C. 5481): I do not indeed feel that merely because the expenditure was made for the purpose of determining whether to bring into existence a capital asset, it should always be considered as a capital expenditure and, therefore, not deductible. ...

Since an ovum is not an organ, an egg donation cannot be considered to be an "organ transplant". ... Since her reasons, for seeking treatment elsewhere, were completely personal, they cannot be considered in the analysis of the "availability" requirement in paragraphs 118.2(2)(g) and (h). ...

.^ [3] Spar included the foregoing clause in its contract with Com Dev, but also included the following diminution modification clause: 12.7 The information detailed in the Contractor’s letter dated April 19, 1990 is considered proprietary to the Contractor or its Subcontractors as the case may be.^ [4] The letter referred to in clause 12.7 and filed as an exhibit in this proceeding reads as follows: April 19, 1990 File: 5050 Ref.: JB-1578 SPAR Aerospace Satellite and Communications System Division 21025 Trans Canada Highway Ste. ... Statement of Proprietary Information In accordance with the conditions of the RADARSAT Contract between SPAR Aerospace and COM DEV, S-700014, Article 12 — Intellectual Properties — this will certify that all equipments, associated Technical Information and Technical Documentation to be generated in performance of the Work and considered deliverable under the contract will utilize computer software, processes, methods, techniques and know-how in existence or residence with COM DEV prior to effective date of the Contract. ...

These amounts remained unpaid at the end of the years in question, and were considered by the Appellant to be uncollectible. ... The amounts falling into category two, therefore, should properly be considered charges for supplies and services furnished by the Appellant to Hollowforms, and are to be treated as being on revenue account. ...

For that purpose an amount shall not be considered to be payable in a taxation year unless it was paid in the year to the person to whom it was payable or she was entitled in that year to enforce payment thereof (subsection 104(24)). ... M.N.R., [1988] 1 C.T.C. 2398, 88 D.T.C. 1271, Sarchuk, T.C.J. said at page 2401 (D.T.C. 1273): The liability of a taxpayer to pay tax under the Income Tax Act has been considered in a number of cases. ...

  [16]         The appellant insists that his cash donation should be considered separately from the alleged gift of the software licences. ... His alleged cash gift cannot be considered in isolation from the overall plan, which the evidence shows was not properly implemented ...

Having referred to the practice of breweries to advance moneys to customers for the purpose of increasing the profits of their trade, the court considered that the appellant company was carrying on not two businesses, brewing and banking, but one business, to which the advancing of money and the provision of banking facilities were a valuable adjunct; that the advances were not permanent investments of capital; and that the losses thereby incurred were losses of money laid out wholly and exclusively for the purposes of the trade. ... (a) Characterization of the Payments In the absence of any judicial authority interest expense must be considered a payment on account of capital although it has been argued that such payments may be incurred in the ordinary course of business. ...