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  [32]         He also considered that 45% of the unskilled labour cost related to the appellant and her ex-spouse ... This criterion applies if, at the time the property was acquired, the taxpayer had considered the possibility of selling the property for a profit if the long-term investment project could not be achieved for whatever reason ...

Rankin, and the changes in American tax law had a negative and unexpected impact on the business, no evidence was presented to show what profit the taxpayer might have earned had these events not occurred and whether the amount would have been considered substantial when compared to his professional income. ... However, section 31 of the Income Tax Act and the cases which have considered that section, apply a test which may, in some cases, seem to be unfair. ...

It drew a distinction between inside and outside directors and stated that, in each of these two categories, a director's personal experience and role within the corporation must be considered. ... In the circumstances, she could be considered an inside director.... [30]          Mr. ...

In response to questioning, under direct examination, respecting her knowledge that the contract considered her an independent contractor as opposed to an employee, she responded:   A         No, I did not understand that.   ... Wiebe Door establishes the well-known “four-in-one test” to be considered in determining whether an individual is an employee or independent contractor. ...

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. ...