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All these expenses were considered personal by the auditor. As they were recorded as a credit to the "due to shareholder's loan" account in the corporation's books, they were considered by the CCRA as a benefit to the shareholder. [14]     As to mileage and parking, these expenses were related to the appellant's commuting to clients' work sites from home. ... She therefore considered that the appellant's usual place of work was not his home and therefore the expenses claimed for commuting to work sites were personal in nature. ... She therefore considered that these items were not used for the purpose of earning income. ...

The Appellant is asking that the documents that were not considered by Mr. East when the Notices of Assessment were prepared be considered; 3.      ... He did not, moreover, state that he had not considered these documents. ...

He moreover said that he considered Suzor-Côté one of the greatest and most complete artists in Canada. [21]     Mr. ... The painting of the monk, can it be considered as a polished work by the master Suzor-Côté? ... And you spoke about paintings from various periods, what other criteria are considered in the market apart from the period? ...

Bayside et al., supra, the Federal Court of Appeal laid out certain matters which should be considered by this Court when hearing these appeals. ... The Minister was said to have considered the salaries of the brothers. ... This is a fact mentioned in the Replies as having been considered by the Minister, but it is unclear if he was aware of the extent of their obligations. ...

They are, however, considered to be responsible to collect Goods and Services Tax (GST) from Avondale Stores Limited (Avondale) on the amounts that they are paid for their managerial services, and to remit it to Revenue Canada. ... She certainly considered that she had little or no discretion as to such things as the store hours, or her own hours of work. ... It is stated in the financial documents, signed by the managers when they are hired, that they are considered to be independent contractors rather than employees. ...

The CRA auditor considered that this line of credit had been used as a chequing account, which means that the interest incurred on the withdrawals is considered to be for new borrowings and not for earning income from sales of real property. ... The CRA considered that the purchase of five (5) computers in four (4) years was unreasonable as the appellant was a real estate agent. ... The CRA considered that the home telephone was personal. Based on the invoice dated May 14, 2006, the percentage to apply for the personal use has been established at 39%. ...

Postdoctoral students are not considered graduate research assistants.   ... Also, UBC no longer considered him to be an employee.   [15]         Mr. ... Rizak considered the stipend that he received to be a non-taxable payment. ...

The epinephrine is then considered as an additive or as an adjuvant. [42]   Paragraph 2(e) of Part 1 of Schedule VI of the ETA should be interpreted restrictively. ... Beaulieu’s opinion: (a) epinephrine does not possess any sedative pharmacological property; and (b) epinephrine is not the main substance of the anesthetics in issue and is considered as an additive or as an adjuvant. [51]   Dr. ... In my opinion, if the main substance of a mixture is a substance referred to in Schedule D to the FDA, then that mixture of substances will be considered a whole and, accordingly, as a zero-rated supply. ...

Larochelle was always considered an employee. Mr. Racine’s testimony [23]   Mr.  ... In addition, during this first step, the actual behaviour of the parties must be considered. ... Larochelle, be considered as self‑employed workers, not as employees of the Appellant. [48]   In addition to Mr.  ...

The purpose of the levy is to fund the cost of removal of the over quota production, and in this sense the levy cannot be considered as a penalty. ... He said that by not paying the levy, the appellant was facing the possibility of losing its quota and, in that sense, the outlay should be considered as a capital outlay. ... For these reasons, I conclude that the levy payment is not to be considered on capital account for tax purposes under paragraph 18(1)(b) of the Act. ...