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"La Ferme": The farm, which the appellant considered to be a business, is located in St. ... Both had been inactive for years and these cannot be considered to be operating expenses. ... Quentin if the deduction of this expense can be considered to be justified. ...

All that was considered was that the development would be phased over a period of years. ... Wakelin said that they were surprised by the generosity of the offer but never seriously considered it, because they intended to develop and rent the property. ... Aside from three or four very basic sketches prepared by Fletcher (Exhibit A-10) no other plans were prepared or considered. ...

Its location was considered to be excellent and Wall Construction hoped to eventually build a new plant thereupon. ... R-1 and A-4) indicate that an application for rezoning would be premature and that industrial development was not considered to be as likely in the near future as sug- gested by Mr. ... Notwithstanding that fact, on August 29, 1975 an offer was received and was seriously considered by the directors of the appellant. ...

Telephone's application for any telephone rate increase and that this cost is considered when a rate increase is granted. ... Telephone considered both its needs and those of the other corporations. ... Although the Courts have considered the term “ordinary course of business" on many occasions,! ...

The latter is determined by facts ordinarily external to the will of an individual, the former depends upon his will. 4.03.2 This does not mean, however, that the intention cannot be considered. ... In the Kallos, (supra), case, intention was explicitly considered. In the Canadian Tax Reporter at 2045, one can read: However, although the individual’s motives and intentions are relevant factors in determining residence they are not essential or conclusive. ... Also as in the present case, Mr Justice Noël considered the facts that the taxpayer visited his family in Toronto three times: The three visits made by the appellant during the period under review were, as far as the Christmas visit is concerned, of such a singular occurrence and as far as the stopovers, of such a transitory and incidental nature, that I fail to see how this could be construed as implying residence in Canada. ...

However, Mr Fordham made the following comments which may be considered as an obiter dictum: However, what has been said in the last two paragraphs is not, without more, determinative of what is in issue. ... However looking at this, more deeply, it seems to me that pursuant to 15(2)(b) the account “Advances to Shareholders” must be considered as loans only at the end of the financial year of the company and it is only then that a series of loans and repayments must be considered. ... Therefore the loan must be considered as it is at the end of the lender’s year and not during the said year: hence, the series of loans and repayments, that the legislator wishes to present seems rather to be those which occurred after the end of the year of the company. ...

What is the line which separates the two classes of cases may be difficult to define, and each case must be considered according to its facts; the question to be determined being — Is the sum of gain that has been made a mere enhancement of value by realising a security, or is it a gain made in an operation of business in carrying out a scheme for profit-making? It is not so much what the taxpayer says his intention was in acquiring the property, it is what he did that must be considered, and all factors antecedent and subsequent to the transaction in question must also be carefully considered. Though there may have been a series of sales and a series of profits which might individually be considered capital gains, the whole course of conduct of the taxpayer must be considered and his avowed intention at the time of acquisition must be tested against all of the surrounding facts. ...

He argues that the amendments are to be considered effective as of the dates of the First Order and Second Order. With respect to the amount of $3,979.86 in the 1992 year, which comprised arrears of mortgage payments, the Appellant submits that it should be considered as regular maintenance. ... Submissions of the Respondent Counsel for the Respondent submits that only the First Order and Second Order are to be considered. ...

In our view, Beatriz’s proposal is logical, since the full amount in question would be available for Maia’s maintenance rather than being reduced by the amount of tax that Beatriz would have to pay if the income were considered hers. t seems fair to us, since it is in no way prejudicial to Roberto. ... The following passage from that agreement leaves room for doubt about the true intention of each party on signing the agreement: [TRANSLATION] In our view, Beatriz’s proposal is logical, since the full amount in question would be available for Maia’s maintenance rather than being reduced by the amount of tax that Beatriz would have to pay if the income were considered hers. ... When a child is emancipated and leaves the custody of the spouse, the problem addressed by Parliament in allowing the deduction of amounts paid for the benefit of the child ceases to exist: from that point on, the former spouse no longer has a duty of care deriving from his or her right of custody, and the support can no longer be considered to be owing or paid on account of that duty. ...

Minister of National Revenue (1989), 89 D.T.C. 663 (T.C.C.), considered a number of authorities, including the comments of Fisher, Q.C. in Bloom. ... C.A.), leave to appeal refused [1946] S.C.R. 462 (S.C.C.), Hogg J., considered a number of these cases in determining whether the appellant was a minister as required by the legislation in question. ... Just.), in which the phrase “regular minister of a religious denomination” was considered. ...