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The error would be an amount of $68,220 which was considered as total business limit on the T7W-T2 form, rather than $94,717 as it appears on the T-7WC. ... It appears clear in this latter case that the question is first and foremost one of fact, and that it is indeed de facto control that must be considered. ... This court considered the concept of “control” in Minister of National Revenue v Dworkin Furs Limited (67 DTC 5035) (1967) SCR 223. ...

The reasons and the decision to make the second reassessments were considered and made at Head Office. ... Bornstein’s comments are effectively an admission that sections 3 and 9 and paragraph 12(1)(x) of the Act were not considered by the respondent in reassessing the taxpayer. ... Similarly, statutory provi sions that are added to the Crown’s pleadings that were not considered by the Minister on assessing require the Crown to convince the Court these provisions support the assessment. ...

This question was considered, whether payments received but yet not earned were to be included in a taxpayer's income in Kenneth B.S. ... The Supreme Court of Canada considered quality of income in Gagnon v. ...

'  This requires the taxpayer to establish that his or her predominant intention is to make a profit from the activity and that the activity has been carried out in accordance with objective standards of businesslike behaviour. [14]               The Court provided the following non-exhaustive list of objective factors that should be considered:-              the profit and loss experience in past years;-              the taxpayer's training;-              the taxpayer's intended course of action; and-              the capability of the venture to show a profit. [15]               The Court emphasized that although the reasonable expectation of profit is a factor to be considered, it is not the only factor, nor is it conclusive.  ...

Roger Leng appeals his income tax assessments for 2001 and 2002 in which the Minister of National Revenue considered his purchase and sale of shares in public companies, primarily in what are commonly referred to as "hi-tech" companies, to be on capital account and not on income account. [2]      Dr. ... Leng took courses in purchasing and selling shares, that he had time to study the market and considered himself knowledgeable. ...

(as he then was) considered the words “or is otherwise subject to taxation in respect of any such property” in section 87 of the Indian Act. ... direct that a broad scope of inclusion be considered as to what constitutes a sufficient connection between the loss of employment and the amounts received. ...

The evidence also shows that the Appellant could not stay at the station during his duty week and that his employer did not reimburse the rent he was required to pay. [10]     Counsel for the Respondent is claiming that under no circumstances can rent be considered a travel expense. ... For this reason, the rent is considered a travel expense in the same way as though he had to travel from the station to any other location for a week at a time as required by his employer. [13]     Therefore, for these reasons, the appeal is allowed with costs. ...

Paragraph 30(1)(c) would then deem such loss to be a business investment loss for the same year. [27] A debt is usually considered to have become a bad debt when the taxpayer has exhausted all legal means of collection. The question of when a debt is to be considered uncollectible is a matter of the taxpayer's own judgment as a prudent, pragmatic businessman. ...

The auditor testified that since the corporation was active at the time and had not been dissolved, he considered those expenses to be corporate expenses and not expenses that the Appellant incurred personally for the purposes of producing income ...   [9]              The Appellant stated that she was unaware that by listing those expenses on the corporate return that they would be considered expenses of the corporation. ...

Headings may also be considered as preambles to the provisions they introduce. ... I say assuming there is a well-founded doubt because it strikes me that apart from the headings referred to, if subsection 20(12) is considered in its entire context the clear inference to be drawn is that the deductions permitted by it relate to computing income from a business or property. ...