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Paris J. considered the meaning of the phrase "an amount paid" in subsection 118.2(2) of the ITA, the meaning of "amount" in section 248 of the ITA and relevant case law concerning the meaning of the phrase "amount paid". ... Rather, Bonsecours [20] should be followed, and all purposes and policies underlying a statute should be considered when interpreting it ...

The Minister considered that this amount had been used to purchase the 75 shares Mr.  ... To answer this question, the following evidence that was offered to me that seems to contradict his testimony must be considered::                       i.                         ...

  [23]     He argued that the contract should not be considered as descriptive of the relationship. ...      [45]     That said, this finding needs to be considered from the perspective of the Sagaz formulation of the question of whether Mr. ...

He contends that, as a non‑resident, none of this income should be considered Canadian income ... (v)     Finally the remuneration in respect of the training in 2000 should be considered as not taxable in Canada as conceded by the Respondent during trial.   ...

The only possible property that the Appellant might be considered to supply as consideration for any additional amount that it might receive under the insurance policy would be its chose in action against the insurance company for such additional amount. ... Subsection 141.1(3) of the Act broadens the scope of what is considered to be in the course of commercial activities to anything done in connection with the acquisition, establishment, disposition or termination of a commercial activity ...

  [46]     The Appellant also considered having cheques being paid to CRL from its customers endorsed directly over to CRA, but because the bank was monitoring the company receivables so closely, the Appellant felt the bank would simply stop this practice if it were to be initiated ...   [50]     Prior to 1999, the Appellant testified that he never considered closing CRL as he had a business plan based on his many years of successfully operating CRL. ...

Because the Appellants considered these Responses to be generally limited and incomplete, this Motion has been brought for:   1.                  ...   [12]     The Federal Court of Appeal considered the function of particulars in Gulf Canada Ltd. v. ...

Hershfield   Appearances:   Counsel for the Appellant: Gavin Laird   Counsel for the Respondent: Selena Sit  ____________________________________________________________________   ORDER           Having heard the Appellant’s motion to have the Respondent’s Reply to the Notice of Appeal struck on the basis that it discloses no reasonable grounds for opposing the appeal pursuant to Tax Court of Canada Rules (General Procedure), Rule 58(1)(b);             And having heard and considered the oral and written submissions of the counsel for the parties;             IT IS ORDERED THAT:   1.                  ... Considerations for allowing amendments to pleadings have been considered by this Court and have not been necessarily altered by the introduction of subsection 152(9). [15]   [48]     The leading authority on whether or not an amendment should be allowed to save a defective pleading is Sweet. [16] In that case Justice Décary set out considerations for allowing amendments that have, as noted above, become known as the Sweet Factors. ...

  [107]   The terms “all” or “substantially all” of the use in the course of gaining or producing income was considered by Associate Chief Justice Bowman in  Pronovost v. ...   [114]   Unlike the situation considered by the Court in Séguin, supra, there was personal use and they had no personal vehicles ...

From the beginning, his salary was considered to be commissioned income ... Argument of the Respondent   [95]          Counsel said that the tax statute must be strictly considered when dealing with a claim for expenses. ...