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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. ... Here there are only two sources to be considered: farming and administration (since I am ignoring rental for the reasons given above). ...

Why, if the appellant considered that he was selling the property to Melcher, he would be concerned about the existence in it of a poolroom was not explained. ... If, subsequent to the disposition of this appeal, what is contained in Exhibit A-3 is considered relevant the parties should reexamine it because what is said therein is riddled with mathematical error. ...

The whole of what transpired may properly be considered. In this regard reference is made to Re Rispin (1912), 25 OLR 633 per Garrow, JA at 642. ... Certain provisions of the BCA must be considered with respect to this submission, namely, section 16 (now section 15); subsections 39(2), (3), (4) and (5) as amended by Statutes of Ontario 1972, c 138, s 13 (now section 37); paragraph 42(a) as amended by Statutes of Ontario 1972, c 138, s 14 (now section 40) and section 135 (now section 133). 16. (1) No act of a corporation and no transfer of real or personal property to or by a corporation, otherwise lawful, that is heretofore or hereafter done or made, is invalid by reason of the fact that the corporation was without capacity or power to do such act or make or receive such transfer, but such lack of capacity or power may be asserted, (a) in a proceeding against the corporation by a shareholder under subsection 2; (b) in a proceeding by the corporation, whether acting directly or through a receiver, liquidator, trustee or other legal representative or through shareholders in a representative capacity, against a director or officer or former director or officer of the corporation; or (c) as cause for the cancellation of the certificate of incorporation of the corporation under section 250. (2) A shareholder of a corporation may apply to a court of competent jurisdiction for an order to restrain the corporation from doing any act or transferring or receiving the transfer of real or personal property on the ground that the corporation lacks capacity or power for the purpose, and the court may, if it considers it to be just and equitable, grant an order prohibiting the corporation from doing the act or transferring or receiving the transfer of the real or personal property, but, where the act or transfer sought to be restrained or prohibited is being or to be done or made under a contract to which the corporation is a party, (a) all the parties to the contract shall be parties to the proceeding; (b) the court in granting the order may set aside the contract and allow the corporation or other parties to the contract, as the case may be, such compensation as may be equitable for the loss or damage sustained by any of them from the granting of the order and setting aside of the contract, other than anticipated profits from the contract. 39. (2) Where authorized in its articles and subject to any restrictions contained therein, a corporation may purchase any of its issued common shares. (3) A corporation shall not purchase shares under this section if the corporation is insolvent or if the purchase would render the corporation insolvent. (4) No purchase of shares shall be made under this section by a corporation unless the purchase is authorized by a resolution of the board of directors. (5) Where a corporation purchases shares under subsection (2), the purchase shall be made at the lowest price at which, in the opinion of the directors, such shares are obtainable, and, (a) pursuant to tenders received by the corporation upon request for tenders addressed to all the holders of the shares of the class and the corporation shall accept only the lowest tenders; or (b) from bona fide full-time employees and former employees of the corporation; or (c) where the shares to be purchased are of a body corporate that is offering its shares to the public, by purchase on the open market. 42. ...

After having considered them, I have decided that the success of these appeals should be decided only on the basis of the evidence introduced before me at the hearing. ... Here, he considered the rental position presented by Mr. Stein. He assumed that Mr. ...

Furthermore, permitting unsued losses to be deducted against income from a “similar business” was considered to be too broad in that it would have produced difficulties in interpretation with respect to the classes or categories of industrial or commercial activities carried on by taxpayers. ... Counsel for the appellant contended that, according to authors Morris and Novis, the Minister’s unofficial position was discussed in 1983 and it was that if a different activity was associated with two similar properties such as the sale and construction of a building, Revenue Canada unofficially considered the two businesses as being the same. ...

If any alternative was seriously considered, it was hand-manufactured by the generalist for testing. ... Razaqpur and Littlejohn agree that scientific research and development is considered to be the application of scientific and engineering principles to the resolution of a scientific or technical problem. ...

Counsel for both parties admitted that payment of the compensation in question had to be considered as having been made to Mr. ... The other sections of Part I of the Regulations need not be considered for the solution of this case, except for section 100, which contains seven definitions. ...

It seems probable that he saw the order, but how closely he read it, what significance he attached to it, and what he considered to be its legal effect are all matters of conjecture. ... The court then considered whether the appropriate remedy would be to exclude the evidence. ...

He was considered to be in the Highly Gifted Learner Range and had a wide variety of special needs which should be met in order to satisfy his intellect. ... However, even though nearly every receipt of revenue is considered income by the taxing authority, not every expenditure in life is deductible. ...

The position advanced was that the similar facts were not logically relevant in determining the matter in issue in the present appeals nor was there any substantial connection between the actions of the Appellants during the period of time previously audited and the circumstances that are before the Court. [11] It is generally accepted that evidence of similar facts is considered collateral and is generally inadmissible unless there is, as Bull J.A. observed in MacDonald v. ... I have considered Erlich’s testimony on this issue and am not at all satisfied that it supports the deductibility of the amounts in issue. ...