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I have considered all these demands for particulars in connection with the subjects just listed and the application of the various allegations of fact contained in the "amended reply to the notice of appeal" in light of the abundant case law cited by counsel for the parties concerned. ...

The parties agree that the headings in this agreement are included for the purpose of facilitating the reading of this agreement and are not to be considered part of the agreement. 2. ...

In the reply to the notice of appeal, the Minister of National Revenue (the "Minister") considered that the appellant’s gains were realized not when the sale agreement was signed before the notary, but either when the purchasers signed an interim agreement and took possession of their condominium unit or when the declaration of co- ownership was registered, because on these dates the sale price would or could have been due. ...

The factors that the courts have most frequently considered include: — what kind of evidence was obtained? ...

The relevant provisions of the Income Tax Act are set out below: 118.3(1) Where (a) an individual has a severe and prolonged mental or physical impairment that has been certified as such in prescribed form by a medical doctor or, where the impairment is an impairment of sight, by a medical doctor or an optometrist, (b) the individual has filed for a taxation year with the Minister the certificate described in paragraph (a), and (c) no amount in respect of remuneration for an attendant, or care in a nursing home, by reason of the mental or physical impairment of the individual is included in calculating a deduction under subsection 118.2(1) for the year by the individual or by any other person, for the purposes of computing the tax payable under this Part by the individual for the year, there may be deducted an amount determined by the formula..... 118.4(1) For the purposes of sections 63, 118.2 and 118.3, (a) a person shall be considered to have a severe and prolonged impairment only if by reason thereof he is markedly restricted in his activities of daily living and the impairment has lasted or can reasonably be expected to last for a continuous period of at least 12 months; and.... ...

Immediately thereafter, Donlee then redeemed the shares held by Holdings at the price of $69.05 a share for a total considered to the appellant of $2,620,201. 6. ...

The payments purportedly made to it by Canron after that date in the amount of $301,501.87 were considered by the Department to have been made directly to Mr. ...

Start-up costs are considered over an extended period of time if evidence is accepted that the farm operation eventually will provide the appellant with the bulk of his income, that is, the commitment of time and capital, the expectation of profit and the change in business direction are such that a favourable comparison over time can be made to the other source of income (Hover, supra, Roney, supra, and Poirier Estate v. ...

I am satisfied that the appellant's notice of motion was fundamentally without merit, poorly researched, ill considered and virtually impossible to support in law. ...

It is necessary to look at the whole financial picture, that is, sales, bonuses, cost of sales as set out in Schedule 1 and Schedule 2 and Exhibit A-4, they all must be considered. ...