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This generosity of the Minister constitutes a potential windfall received by the Appellant without any reliable evidence for such expenses to have been considered. ...

At its meeting of May 8, 1985, Nordair Inc.’s new board of directors considered the question whether certain incentives for the business’s executive staff were appropriate and to this end decided to award options to purchase 275,000 Nordair Inc. shares (Exhibit A-1, tab 5). ...

I considered not accepting him as an expert in this case despite his otherwise impressive credentials and experience. ...

  [13]          The purchase of term deposits cannot, in my opinion, be considered a deductible expense in this case, under paragraph 18(1)(a) of the Act, even if these term deposits were mortgaged in favour of the Bank and the appellant temporarily lost enjoyment. ...

The assessor considered whether to apply the late and unlamented REOP principle, (which has been given a decent burial by the Supreme Court of Canada). ...

At that time, the Appellant was reassessed for unremitted source deductions for certain family members who were not considered to be employees but whom the Canada Revenue Agency determined were employees. ...

Furthermore, the Minister considered that Class 29 of Schedule II of the Income Tax Regulations (Regulations) did not include artificial snowmaking equipment and that that equipment did not constitute qualified property within the meaning of subsection 127(9) of the Act. ...

  [7]               Because of this conclusion several cases submitted by respondent's counsel need not be considered: Inco Limited v. ...

Livingston, 2008 DTC 6233, Justice Sexton of the Federal Court of Appeal laid down the criteria of application of section 160 in connection with the purpose and spirit of subsection 160(1):   [9] The   Tax Court Judge   determined that in order for subsection 160(1) of the Act to apply, the following four criteria must be met:   1)             There must be a transfer of property;   2)      The parties must not be dealing at arm's length;   3)      There must be no consideration or inadequate consideration flowing from the transferee to the transferor (I would note that the trial judge considered the test to be “No consideration or inadequate consideration flowing from the   transferor   to the   transferee ” [emphasis added]: this is a mistaken quotation of the test as cited in   Raphael v. ...

Gotlieb's Testimony: [17] He considered the KDS a memory aid and information retrieval system. ...