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Subsection 60.1(3) requires that “where a written agreement or order... provides that an amount paid before that time... is to be considered to have been paid and received thereunder...”. Thus the subsection requires that the agreement must refer to past payments which are “to be considered to have been part and received thereunder.” ... It is not a statement that they are considered to have been paid and received under the Order or, on July 12, 1995 under the Interim Agreement. ...

(resident expenses) 1,200.00 (personal credit card charges) 1,573.00 Unvouched expenses considered personal 6,701.00 Cheque charged to casual wages deposited by shareholder 250.00 Vehicle expense paid by Sat-Tech Distributors Inc. for Unique Auto 8,218.00 Total $32,059.44 7 987 respecting subsection 15(1) of the Act Missing corporate deposits for payments received on account $ 7,214 Residence expenses 1,100 Personal credit card charges 1,700 Vehicle expenses paid by Sat-Tech Distributors Inc. for Unique Auto 4,714 Welder expenses by corporation and transferred to shareholders 1,725 Unvouched expenses considered 8,050 Total $24,503 1987 respecting subsection 15(2) of the Act Re Shareholders Loan Account Cash paid out: non deductible (25 per cent of $5568.18) $ 1,392 Cash paid out: non deductible (25 per cent of $6273.72) 1,568 Reduction of amount included in income under subsection 15(2) of the Income Tax Act relating to reduction of debt owing by H. ...

(iv.1) that would be considered to be withdrawn by the taxpayer as an eligible amount (within the meaning assigned by subsection 146.01(1)) less than 90 days after it was paid, if earnings in respect of a registered retirement savings plan were considered to be withdrawn before premiums paid under that plan and premiums were considered to be withdrawn in the order in which they were paid.... [8] On November 28, 1996, the appellant withdrew $6,000 from his RRSP with the insurance company as a withdrawal under the Home Buyers' Plan. ... This eligible amount is then considered an excluded withdrawal under the definition of "excluded withdrawal" in the same subsection. ... (f) where (i) an individual receives an eligible amount in a particular calendar year, (ii) at a particular time in January of the following calendar year (or at such later time in that following year as is acceptable to the Minister), an individual receives another amount that would, if the definition "eligible amount" in subsection (1) were read without reference to paragraph (i) thereof, be an eligible amount, and (iii) the request described in paragraph (a) of the definition "eligible amount" in subsection (1) pursuant to which the other amount was received was made before the end of the particular calendar year except for the purposes of this paragraph and paragraphs (a) to (h) of the definition "eligible amount" in subsection (1), the other amount shall be deemed to have been received by the individual at the end of the particular calendar year and not at the particular time. [16] An eligible amount may be received in January and be considered an eligible amount for the previous year if the application for withdrawal was made before the end of that previous year. ...

Paragraph 4 of the notices of appeal: The expenses of $285,339 and $41,039 claimed for renovations, maintenance and repairs should therefore be considered entirely by the Department as current operating expenses, and thus entirely deductible in the current year, and not as capitalizable outlays, as the Department claims. ... In the first case, it was decided that the appellant owned a virtually new building and that the disputed expenses pertaining thereto could therefore very well be considered capital outlays and not current expenses. ... Consequently, the Court cannot accept the appellant François' reasoning that the normal capital value should be considered in the instant case. ...

Thérèse Godbout each received the $20,221.58 as agreed; (f) The “Restaurant” duly included the $118,619.40 (sic) in its 1981 taxable income and was at no time considered the owner of the amounts received directly by Mr. ... Interpretation Bulletin IT-365R of March 9, 1981. 4.03 Analysis 4.03.1 The essence of the problem is whether compensation received by (from)* [1] someone other than the employer can be considered a “termination payment” within the meaning of subparagraph 56(1)(a)(viii) and subsection 248(1) cited above. ... After that date, any payment of that sort must be considered a retiring allowance and the whole amount is taxable according to subparagraph 56(1)(a)(ii) and the new definition of “retiring allowance" in subsection 248(1). 5. ...

The problem in fact concerns only the value of the piece of land (48.41 acres). 3.02 The appellant considered the highest and the best use of the subject property as residential and agricultural, and the respondent considered it only as agricultural. ... Because these 4.38 acres formed an irregular area, they should be considered as 4 acres at most. ... This was considered as superior to the subject property and there was an adjustment made for a loss of $1,000. 4. ...

Basically, the appellant was considered a caterer, which was also how she advertised herself (see Exhibit I-11). ... It was not shown how a committee of volunteer parents looking after hot meals for students could be considered to be representing or to be part of a school authority. Insofar as the committee is not so considered, the exemption provided for in section 14 cannot apply, and the appellant's supply of the meals in those cases must be considered a taxable supply that entitles her to ITCs unless it can be argued that another provision covering exempt supplies, such as section 12 of Part III of Schedule V, is applicable. ...

Justice Woods was dealing with a factual situation that caused the phrase “could reasonably be considered to be attributable” to have ambiguity. ... Justice Woods was faced with two possible interpretations of the phrase “could reasonably be considered to be attributable”. ... Applying the facts of this case to the phrase, “could reasonably be considered to be attributable”, I am unable to discern any imprecision or equivocation. ...

I would ask that an extension of time to file be considered under this circumstance. ... Acorn, and those considered pertinent by counsel for the Minister, and then the Court reserved its decision. ...

However, it had never been considered at any time in the course of offering tax advice to Dr. ... It is obvious it never was considered by John Robinson, C.A. who was the person offering income tax advice to Dr. ... Lee considered any possibility of selling the corporation to any other practising physician as being extremely remote. ...