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Fletcher's radar screen in May 1993 when she made the offer, nor in September 1993 when she moved in, nor in November 1993 when the formal transfer of title took place. [21]          For there to be a secondary intention, there must be some evidence that the possibility was considered at the time of acquisition. ...

Each of them was reassessed under section 15 of the Income Tax Act (the Act) to include in his income amounts which the Minister of National Revenue considered to be shareholder benefits conferred on them by Roberts Properties Inc. ...

The Minister indicated that he had carefully considered the facts and reasons set forth in the Notice of Objection and confirms the reassessment on the basis that this equipment, which was acquired by Inter-Teck Oil Limited Partnership, has been determined to be valued at $422,000.                 ...

The Queen, 83 DTC 5365 where the effect of a deeming provision in a Saskatchewan statute was considered in relation to when an estate became indefeasibly vested. ...

I cannot understand why the Minister considered this provision in assessing. ...

The primary intention underlying the taxpayer's activity must be considered in determining the existence of a reasonable expectation of profit. ...

If there is no employment contract and the job is only on a volunteer basic, one cannot deduct any expenses (even one do not get reimburse) [sic] because the expenses are not considered incurred for the purpose of earning employment income. ...

Johnson started again to work for the School Board, Mutual Life and the School Board considered the employment to be rehabilitation for purposes of the Policy. ...

Recognizing capital losses created by such outlays is a theoretically acceptable result and one permitted by subparagraph 40(1)(b)(i) which was not considered in Cadillac Fairview. ...

He had known them since 1974 and considered he had a special relationship with them. ...