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The other aspect to be considered under this heading is whether the taxpayer made any "special efforts to find or attract purchasers". ...

Compliance with the provisions of the Income Tax Act is the only criterion that must be considered in determining whether an assessment is well founded.  ...

Before: The Honourable Judge Paul Bédard   Appearances:   Agent for the Applicant: Christian Boivin   Counsel for the Respondent: Marie-Aimée Cantin____________________________________________________________________   ORDER             Upon application for an Order extending the time within which an appeal from the assessments under the Income Tax Act for the taxation years 1998, 1999 and 2000 can be brought;             And upon hearing what was alleged by the parties;             The application is allowed and the time within which an appeal can be brought is extended to the date of this Order, the Notice of Appeal accompanying the application being considered valid on the date of this Order, if and when the Applicant requests that this appeal be governed by the informal procedure or the general procedure and that the appropriate filing fee is paid to the Court Registry by February 24, 2004.    ...

It should also be noted that irrespective of CRA policy on this issue, under general income tax principles loan proceeds are not considered income, and loans are not taxable under section 3 of the Act. [24]     In The Queen v. ...

One of the factors to be considered by the Court is the taxpayer's reasonable expectation of profit from this activity. [18]     Counsel for the Minister maintains that the fact that the Appellant's daughter occupied the property constitutes a personal aspect, which makes it necessary to decide whether the taxpayer had a reasonable expectation of profit during the years at issue. ...

Picard considered the periods in issue very active for the business and believed that the payor had a great need for his services. [11]     At the hearing, Mr. ...

It is at that point that the Appellant had a serious discussion with his son and that the transfer of the two motor vehicles was considered. ...

As part of this review she considered the testimony given, the payroll register, Ms. ...

  [30]     The Court is satisfied that the Minister was correct in concluding that the amounts in question allegedly paid in pursuance of the order of June 18, 2002, in the year 2000 are not considered to have been paid and received thereunder and therefore are not deductible under paragraph 60(b) of the Act ...

M.N.R. [4] [15]     The Federal Court of Appeal considered the definition of "the new work location" in subsection 62(1) of the Act, as that provision applied before 1998, to determine whether the distance between a taxpayer's "old residence and his new work location is not less than 40 kilometres greater than the distance between his new residence and his new work location" should be calculated along a straight line or along the shortest normal route. [16]     I do not believe the Giannakopoulos case is of any assistance in deciding the appeal at bar. ...