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The appellant should be considered a director in this case because everyone's mindset was applied and directed to that end. ... Rip, J. at pages 2274-78 (D.T.C. 1023-28) considered the validity of a notice of assessment virtually identical in wording (except the amounts and the names of the taxpayers) to the one at bar. ...

They admit that they did not have more than five full-time employees when considered separately but do meet the requirements of subparagraph 125(7)(e)(ii) when considered jointly. ...

If we considered only the wording of the agreement, we should probably conclude that the payment of the sum of $75,000 was in the nature of a retiring allowance within the meaning of subsection 248(1) of the Act. ... This question as to the true nature of a payment made to a person when he leaves a business in which he has a major financial interest was considered by the chief judge of this Court in Brodeur v. ...

Land assemblies have always been considered to be bad comparables. The price paid may actually be far in excess of the fair market value and can amount to double or even more, depending on the circumstances. Finally, by the admission of counsel for the respondent himself, the value established for municipal taxation purposes in the year in question is in general considered to be reasonably accurate. ...

Since the enactment received Royal Assent on March 30, 1983, I have no doubt that section 7, which was relied upon by the appellants, can be considered. Section 15, on the other hand, which was also raised by the appellants, may be considered since the assessments were dated May 14, 1986 and were the appellants' causes of action. ...

Where the development of the basic food product still involves the growing process and natural biological changes as opposed to artificially manufactured foods or mere processing, I do not feel that, generally speaking, the activity would be considered by the general public anything other than agricultural in nature and would, therefore, generally be considered as a farming operation. ...

Classes of Farmers The Supreme Court of Canada considered this “awkwardly worded and intractable" provision (then subsection 13(1)) together with the whole of the Income Tax Act in William Moldowan v. ... Justice Ryan of the Federal Court of Appeal considered the possibility that a source may be a source of income in a particular year although it did not yield a profit in that year and therefore to determine the chief source for a year it appears pertinent:... to look at each of the taxpayer's sources from the point of view of capacity for present or future profit or for both when one is seeking to determine his chief source of income in that year. ...

Cruickshank said that in 1978 he again considered the appellant's involvement in a ranching operation with Mr. ... But, if what is sold relates to the use of land, including excavation for gravel, that is a profit à prendre, thus taxable income, whether or not the sale is considered to be a "business" (under the provisions of the old paragraph 139(1)(c) or the new subsection 248(1). ...

IT-442 quoting paragraph 27: Although the length of time that the account is in arrears is generally an important consideration in deciding whether the account is doubtful of collection, in certain circumstances, a lengthy delay may occur without the account being so considered.... ... All those over 60 days were considered in the computation of the open line credit permitted by the bank to the appellant. ...

Reference was made in the Minister's reply to notice of appeal to an "alternative" — that is, in the event the Court found the farming activity to be considered a business, that only the restricted farm losses should be allowed. ... Even if the losses experienced during the years in question could be considered "start-up costs", there is authority that 10 or even 15 years may not be excessive for an operation to experience such costs, providing the operation is basically sound.* [3] Second, the appellant in Gorjup (supra) to some degree did "change direction" (and I quote):... ...