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(c) Even before the three-month period was up for closing the deal, he had signed a new ten-year lease with Consumers Distributing Company Limited (which he considered a first class tenant at the time) for $40,000 per year on a net-net-net lease basis — a considerable improvement. ...

Therefore it must be considered that all its activities were properly attributed to income account and correctly treated on an accrual basis. ...

Act in force on November 12, 1981. 56. (1) Without restricting the generality of section 3, there shall be included in computing the income of a taxpayer for a taxation year, (a) any amount received by the taxpayer in the year as, on account or in lieu of payment of, or in satisfaction of, (ii) a retiring allowance, other than an amount received out of or under an employee benefit plan, (viii) a termination payment; 248. (1) “termination payment", for a taxation year, means an amount equal to the lesser of (a) the aggregate of all amounts each of which is an amount received in the year in respect of a termination of an office or employment, whether or not received pursuant to an order or judgment of a competent tribunal, other than (i) an amount required by any provision of this Act (other than subparagraph 56(1)(a)(viii)) to be included in computing the income of a taxpayer for a year, (ii) an amount in respect of which an election has been made under subsection 40(1) of the Income Tax Application Rules, 1971, and (iii) an amount received in the year as a consequence of the death of an employee, and (b) the amount by which 50% of the aggregate of all amounts each of which is the amount that may reasonably be considered to be the employee’s salary, wages and other remuneration from an office or employment for the 12 months preceding the date that is the earlier of (i) the date on which the office or employment was terminated, and (ii) the date on which an agreement, if any, in respect of the termination was entered into exceeds the amount determined under paragraph (a) for each previous year in respect of that termination whether the recipient is the officer or employee whose office or employment was terminated or a dependant, relation or legal representative of the officer or employee; B. ...

The following criteria should be considered: the profit and loss experience in past years, the taxpayer’s training, the taxpayer’s intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...

The respondent's position is the fact that the appellant’s farm business, although it had a reasonable expectation of profit, was nonetheless, a sideline business or was subordinate or auxiliary to the appellant’s full-time employment and could not be considered “‘a chief source of income". ...

Mr Justice Décary in fact, concerning a payment of $20,000 said: It is my considered opinion that the decision of the Court of Appeal as to the nature of the $20,000 for purposes of civil relations between the parties cannot be ignored in establishing the tax nature of this amount. ...

Even if holding the five acres could be considered as a motivating factor in the appellant’s acquisition of his one-third undivided interest in the land, a proposition which in my opinion is not supported by the facts, it would at best be a contingency plan and speculative in nature because the five acres were to be used by the appellant only if circumstances made it necessary for him to do so. ...

The phrase was considered by the Exchequer Court of Canada in MNR v James A Taylor, [1956] CTC 189; 56 DTC 1125, and Thorson, P commented at 199 [1131]: It is, I think, plain from the wording of the Canadian Act, quite apart from any judicial decisions, that the terms “trade” and “adventure or concern in the nature of trade”, are not synonymous expressions and it follows that the profit from a transaction may be income from a business within the meaning of section 3 of the Act, by reason of the definition of business in section 127(l)(e), even although the transaction did not constitute a trade, provided that it was an adventure or concern in the nature of trade. ...

If, as Revenue Canada indicates, mortgage payments made in the year of initial purchase are considered to be “amounts to acquire an owner-occupied home’’, then mortgage payments made in a subsequent year should also qualify (assuming they are made in the specified period) as the character of a mortgage payment is the same whether made in the year of initial purchase or a subsequent year. ...

Mrs Goldhar was required to pay her own expenses — they were not even considered to be expenses of Del Realty. ...