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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. ...

He also argued that even if the Court was not bound by the relevant Information Circular, his course of conduct and his spirit of cooperation should be considered as factors bearing on the issue of penalty. ... It is clear that this payment could not be considered as a gift. The Appellant recognized that when he was first retained by Mr. ...

FACTS [5] From the various documents and testimony at trial, the following facts were assembled, determined to be relevant and considered by the Court. ... It must be considered in light of the successful appeal on the issue of sub-contractor expenses and the unique facts in this appeal. ...

</p>] 37 Counsel for the Respondent went on to compare the situation in the present case with that considered in each of the above-mentioned cases. ... Judge Lamarre Proulx of this Court commented as follows at page 155: On the evidence that was before me, I can only conclude that the Appellant's activities do not meet the threshold required for him to be considered as ‘carrying on a business’. ...

Pat Hasiuk: Re: Corporate Income Tax Returns for 1987, 1988, 1990 and 1991 Following our examination of Nasha Properties Ltd. for the above noted years, we are proceeding to initially assess the following as taxable income of the corporation for the years given: 1987 Unreported business income from various lot sales (see attached schedules) $43,797 Unreported taxable capital gain on the sale to Edison Carvalho ($54,439- $32,000- $4,122) × 50% $9,159 $52,956 1988 Unreported business income from various lot sales (see attached schedules) $72,594 1990 Unreported business income on the sale to Robert Hasiuk (see attached schedules) $14,599 Unreported taxable capital gain (reserve of $4,122 × 75%) 3,092 $17,691 1991 Unreported business income on the sale to Bill Hasiuk (see attached schedules) $19,599 The completion of our examination should not, however, be considered as permission to destroy any books and records. ... My examinations of the records shows that the Minister considered the application for an extension of time for the 1987 and 1988 taxation years, but refused it because it was not filed within the time limited by subsection 166.1(7) of the Act. ...