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Bozyk considered that it was more fair to the Appellant to take the business kilometres as estimated by Mr. ...

The tax advantage which is received from gifts is not normally considered a "benefit" within this definition, for to do so would render the charitable donations deductions unavailable to many donors. 21         In Friedberg, supra, there was no evidence of a prior transfer of ownership to the alleged donor for one of the two gifts. ...

The evidence suggests that it was to be considered at a future time and given effect on such terms as would best resolve Frank's concerns based on how things unfolded. ...

The question of that Justice having some potential conflict of interest was considered by him on that day and he decided that day, to withdraw from hearing this motion. ...

That offer, by way of a lump sum, essentially means that Manulife is paying the past benefits plus interest, 75% of the present value of the future benefit and about $6,455.00 for costs, GST and disbursements; an amount that I considered low given the extent of my time in this file. [15]          This lump sum settlement, less $18,068.97 for legal fees paid to the appellant's solicitors, was accepted by the appellant and a very broad release of all claims was signed by her in favour of Manulife. [16]          The remainder of the documents in the Common Book of Documents are lengthy letters between the appellant's solicitors and Revenue Canada in which they put forward their respective positions. [17]          I shall deal first with the issue under paragraph 6(1)(f). ...

The Tax Court Judge had considered himself bound by another decision of the Tax Court of Canada in Trynor et al. v. ...

Later on he went to say at page 193:                 For the purposes of the Income Tax Act, therefore, a bad debt may be designated as the whole or a portion of a debt which the creditor, after having personally considered the relevant factors mentioned above in so far as they are applicable to each particular debt, honestly and reasonably determines to be uncollectible at the end of the fiscal year when the determination is required to be made, notwithstanding that subsequent events may transpire under which the debt, or any portion of it, may in fact be collected.                 ...

This seems to me to indicate that the MD considered any operator to remain under the "direction, management and control" of the Appellant. [22]          I noted also in Clause 16 that it was the Appellant who was required to ensure that the assigned operator, who I take it to be the Worker, attend all MD safety meetings. [23]          Clause 18 of the agreement required the Appellant (the contractor) to commence and discontinue work upon the direction of the MD Director of Field Services. ...

RESPONDENT'S SUBMISSIONS: [29]          Counsel for the Respondent agreed that the three factors considered in determining the applicability of issue estoppel were those presented by Appellants' counsel, namely whether the same question arose in two different actions, whether the judicial decision was final and whether the same parties were involved. ...

Papp expressed his views on prescribed versus recommended medicines, suggesting he could use these terms from a medical perspective interchangeably, but for what he considered the legal connotation of "prescription". ...