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When personal elements are considered in the search for objective manifestations of the purpose for incurring particular expenses, there should be little need to invoke a reasonable expectation of profit test as a means of introducing objective testing of a taxpayer's purpose in carrying out an activity or incurring an expenditure in pursuit of it. [12] [26]          In addition to the possibility of applying paragraph 18(1)(a) to more closely scrutinize a taxpayer's purpose, more resort in these types of cases might also be had to paragraph 18(1)(h) of the Act which denies the deduction of personal living expenses. ...

Although the appellant maintained that the amount was always considered to be an asset of Conforbel, counsel for the respondent urged me to caution, because the financial statements were not reliable; they had not been audited or even reviewed. ...

The Court will presume that he still had his hearing aid on and that because the father was not looking at him he was not able to understand. [64]          The Court takes into account all of the factors considered here, takes into account the cases, where some were successful and some were not, the Court has to look at them and interpret them in light of the facts given in this particular case. ...

In particular, the appellant argued that there was not a sufficient relationship of subordination between it and the worker for it to be considered an employer for the purposes of subsection 5(1) of the Act. [10]          The respondent, for his part, contended that the worker's internship was insurable under paragraph 6(b) of the Employment Insurance Regulations (" Regulations "), notwithstanding any notion of subordination, as section 6 of the Regulations includes in insurable employment employment which would not otherwise be insurable under subsection 5(1) of the Act alone. [11]          The letter dated May 11, 1998, from CIDA to the president of Mondo-Tech reads in part as follows: [TRANSLATION] We are pleased to advise you that a contribution of CAN $150,000 has been approved for the aforementioned project as part of CIDA's International Youth Internship Program. ...

Decision [15]          There are four periods that can, initially at least, be considered separately in examining whether the Applicant meets the requirements of subsection 167(5). ...

Giglio resigned in fact, if not in law, as director of Nu-West before 1992. [6] Sobier, J.T.C.C. considered the facts before him as well as the provisions, in particular, section 121, of the Ontario Business Corporations Act ("OBCA") dealing with the resignation of a director. ...

I found they were employees of the Club and were, therefore, in insurable employment notwithstanding the wishes of all parties for them to be considered as independent contractors while teaching lessons within the structured programs offered by the Club. ...

He suggested that legal costs are now considered to be also deductible if they are incurred to claim an alimony pursuant to a divorce. ...

These are: (i) January 19, 1994 $786.19 cheque (ii) February 7, 1994 $5,673.42 cheque (iii) May 4, 1995 $11,353.11 (this----- from a    cheque in the amount    of $38,703.09 was    applied to 1993    arrears) (iv) May 18, 1995 $9,042,69 (GST credit held by    Revenue Canada and    applied in 1993    arrears) (v) July 10, 1995 $17,553.57 (S.R.T.C. held by    Revenue Canada    applied in 1993)___________ Total $44,408.57 [37] Both parties agreed that the statement in the Canadian Encyclopedic Digest, Western 3rd Edition, under the heading: "Appropriation of Payment", paragraph 92 is a correct summary of the law and reads: § 92 It has been considered a general rule since Clayton's Case, that when a debtor makes a payment, he may appropriate it to any debt he pleases and the creditor must apply it accordingly. ...

First of all, that fact was considered for the purposes of a previous decision and was not held against the appellant because she was being trained at the time since she had no experience in the field. ...