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However, he also said that in discussions leading up to the agreement John was not "comfortable or happy with the amount that was considered to be the fair market value of the Shares". ...

These circumstances must be taken into account, but must be considered against an objective “reasonably prudent person” standard.   ...

It was held that an amendment to section 83 of the Income Tax Act applied because it did not operate retrospectively but merely provided that for future years the new rules should apply. [8]               The press release announcing the changes to section 10 stated:                 In circumstances where a taxpayer has claimed an inventory write-down for property held as an adventure in the nature of trade for a taxation year ending on or before today, the amount reported as the fair market value of the property (or such revised amount as determined on assessment or reassessment by Revenue Canada) will be considered to be the taxpayer’s cost of the property for the purposes of computing any income or loss that may be realized in the future. [9]               Intertan Canada Ltd. v. ...

  [4]      The only issue in this case is whether the management fees that the four Appellant corporations paid to a related corporation should be considered part of the four corporations' cost of labour when calculating that cost for the purpose of  determining their manufacturing and processing profits ...

    [49]          Finally, the appellant is seeking to add some invoices that were not considered at the time of his audit. ...

I have considered the Appellant's claim with respect to "chief source of income" by applying the three-pronged test from Moldowan as if there were no issue concerning proof of payment. ...

Russell’s evidence must be considered in light of a certain bias because he is personally involved in this program. ...

While disavowing the appellant was "in the business of" producing the film, it was admitted on behalf of the respondent that: —the appellant had participated in the film’s production as an executive director;-the appellant’s film interest was considered to be tangible property which was why it was treated as capital property for capital loss purposes for 1989;-active filming stopped sometime in the fall of 1984, the marketing steps as described by the appellant had occurred and the project was not abandoned in 1984 but at a later time; —the appellant acquired the film interests for the purpose of earning income; and that-the film was not viewed prior to the issuance of the reassessment under appeal. ...

(f)      The assets acquired before 2000 should not be considered in the net worth calculations as they are not reflective of the income earned in 2000.             ...

Lacasse’s accountant did acknowledge that he or his firm should earlier on have recognized and considered the capital dividend account as part of the transactions in the circumstances. ...