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I emphasize the word “all” in the previous sentence because, although judicial independence is usually considered and discussed in terms of the relationship between the judiciary and the executive branch, in this appeal the relevant relationship is between the judiciary and Parliament. ...

The following criteria should be considered: the profit and loss experience in past years, the taxpayer’s training, the taxpayer’s intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...

All items currently reclassified were already considered as I.T.C. eligible on previous reassessment. ...

Meanwhile Kondrat considered his wife to be uncooperative and thought that "if Karon could pay her something she’d release against Karon”. ...

[Alternate plea] With reference to the alternative plea in the statement of defence, if it may be considered as an allegation of an "assumption"... ...

This argument was considered in French Shoes and in Woodward. In French Shoes, Teitelbaum, J. relied on the Interpretation Act, R.S.C. 1970, c. 1-23, to find that the new paragraph 12(1)(x) did not change the law. ...

At this time the Penturns considered that Henry was indispensable to the operation and sale of London Loan Ltd. ...

For the years 1980 to 1982, subsection 18(2) of the Act provided as follows: 18 (2) Notwithstanding paragraph 20(1)(c), in computing the taxpayer's income for a taxation year from a business or property, no deduction shall be made in respect of any amount paid or payable by the taxpayer in the year and after 1971 as, on account, or in lieu of payment of, or in satisfaction of, (a) interest on borrowed money used to acquire land, or on an amount payable by him for land, or (b) property taxes.... if, having regard to all the circumstances, including the cost to the taxpayer of the land in relation to his gross revenue, if any, therefrom for that or any previous year, the land cannot reasonably be considered to have been, in that year, (c) used in, or held in the course of, a business carried on in the year by the taxpayer, or (d) [Repealed] (e) held primarily for the purpose of gaining or producing income of the taxpayer from the land for the year. except to the extent.... ...

The following criteria should be considered: the profit and loss experience in past years, the taxpayer's training, the taxpayer's intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...

The Minister of National Revenue has considered the facts and reasons stated in your notice(s) of objection and hereby confirms the said assessment(s) as having been made in accordance with the provisions of the Income Tax Act, for the following reasons. ...