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[Translation]:—This appeal is from an assessment made by the respondent dated November 29, 1984 by virtue of which the sum of $13,251.67 received by the appellant during the 1982 taxation year was considered to be income for the purposes of the Income Tax Act (the Act). ...

The Appellant considered letters she wrote to the Regional Office of Revenue Canada and to Active Bailiff Service Limited were a valid Notice of Appeal. ...

(v) eliminating (bowels or bladder functions), or (vi) walking; and (d) for greater certainty, no other activity, including working, housekeeping or a social or recreational activity, shall be considered as a basic activity of daily living. ...

Catharines, Ontario and 6 Blue Jay Avenue, Brampton, Ontario. 4 With respect to 110-114 Queen Street, this was commercial property which had been tenanted. 5 With respect to 11 Fourth Avenue, attempts were made to re-zone this property for commercial use, but were ultimately proven to be unsuccessful. 6 With respect to 135 Hartzel Road was a commercial property for which problems were experienced with the tenant who moved to California. 7 With respect to 6 Blue Jay Avenue, this property was purchased with the intention of the Appellant's children residing there, but ultimately did not occur. 8 When each of the above properties were sold the Minister considered the profits on income account and not capital gains as alleged by the Appellants and assessed each with his or her share of the profits as income. ...

To support its argument, the Appellant pointed to case law which considered comparable wording ... The Queen, [15] this Court considered the wording “reasonably be attributed” then contained in subsection 55(2). ...   [39]         The Appellant also referred to a document in which the Minister considered the meaning of the phrase “can reasonably be considered to relate” in the context of subsection 152(4.3). ...

What I do not find however is that I can draw the inference that this tax savings from the share reduction can reasonably be considered to be one of the main or principal reasons for Lopa’s separate existence for 1991 and 1992. ... However, whatever factors are considered, they must show that a person or group of persons has the clear right and ability to elect the board of directors (Silicon Graphics [2002] FCA 260, para [67]). ... The appellant did not challenge the relevance of the factors considered by the trial judge. ...

Of significant importance is that work in progress should be considered as part of the assets of a law partnership. ... Analysis Inasmuch as no current cases were cited to the Court by either party on this point and as there does not seem to be any reported case that is to be considered a review of the law and the problem may be best considered in detail under various headings. 1. ... For this reason, the cost for files in progress cannot be considered as a non-deductible capital outlay. ...

In reaching this conclusion I have considered the following. [50]          There are some factors which supported the Appellant’s position. ... Although one of the factors which must be considered is the regularity and length of time the Appellant spent in Canada, it is nevertheless only one of many factors which must be considered. ... In that, he was not atypical of his contemporaries and the relevant factors must be considered in that context. ...

In that reference he said that when determining the income earned or realized of a parent corporation in a corporate group, income earned or realized and losses within the corporate group consisting of the corporate parent and its direct and indirect subsidiaries, must be considered. ... He said: The reference to “any corporation” permits the income earned or realized or loss incurred by a direct or indirect subsidiary corporation to be taken into account in determining the part of the gain on the shares owned by the parent corporation that could reasonably be considered to be attributable to income earned or realized and the part that could reasonably be considered to be attributable to something else. ... Subsection (2) of Section 55 provides that the portion of a dividend “that could reasonably be considered to be attributable to anything other than income earned or realized by any corporation after 1971” shall be deemed not to be a dividend but to be proceeds of disposition. ...

Cassell would be considered an employee, the Appellant submits that the factors described in Wiebe Door Services Ltd. v. ... Cassell would reasonably be considered to be an employee of WPNL. I reach this conclusion on the basis of the following considerations: 1.                  ... Cassell would reasonably be considered to be carrying on a services business on his own account if ICL did not exist. ...