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Taxes, financing cost, etc of the former home before the sale cannot be considered as selling costs. ... In my opinion, they cannot be considered as “in respect of the sale”. Unfortunately, the expenses of $431.79 cannot be considered as deductible. ...

The Board considered mainly 1972, 1973 and 1974. Living expenses (hotel and meals)—1972: $6,720; 1973: $7,250; 1974: $7,500. ... An amount of $750 is considered reasonable for each of these years. Depreciation The purchase of a- “Thunderbird” for $9,500 in 1973 is definitely considered unreasonable. ... The taxpayers had not shown any evidence of requiring a car considered to be a luxury car for the needs of their businesses. ...

He was an industrious person and there is uncontradicted evidence that he has put in long hours on farming chores which can hardly be considered as recreational. ... Nor can the appellant be considered, as was Mr Brown, as an absentee farmer, since the appellant worked on the farm every day — admittedly on off hours. ... Though the appellant’s activities must be considered as farming, he cannot be considered as having a reasonable expectation of profit in 1967 and 1968. ...

The amount of $650 is disallowed and must be considered as revenue. 6. ... As the burden of proof is on the appellant, this amount of $822 is disallowed and must be considered as revenue. 7. ... This amount is disallowed and must be considered as revenue. 7.2 Unidentified cheque April 24—$204-e- As the appellant does not remember what this amount represents, it must be disallowed and considered as revenue. 8. ...

Counsel for the appellant considered that the appeal for the 1967 taxation year was invalid because it was from a nil assessment for that year, and asked that it be quashed. ... These loans made by the company to its customers might conceivably be considered as expenditures made by the company for the purpose of earning income from a business, but the advances made by the appellant to Waite, Reid and Company Limited cannot by any standard be considered as general expenses incurred by the appellant for the purpose of earning income from a business. ... Just as the appellant cannot be considered as operating an overall brokerage business independently of the companies incorporated for that purpose, the appellant cannot be considered as carrying on a loaning business independently of Waite, Reid and Company Limited because there is nothing in the evidence which indicates that the appellant made any loans other than to Waite, Reid and Company Limited in which the appellant is the principal shareholder. ...

Point at Issue The question is whether the appellant is entitled to claim a capital cost allowance on the personal automobile of the company sales manager for the 1974 taxation year, and whether the cost of $5,520 paid by the company should be considered part of the manager’s salary and therefore deductible. ... Moreover, the fact that the amount paid can be considered a shareholder’s benefit does not take away the appellant’s right to the deduction, inasmuch as this benefit constitutes a disbursement for the appellant and is not considered a dividend. ... Should not the payment of the insurance policy premium be considered in the same way as the payment of the debt? ...

The result is that the sources of income of a corporation must be looked at, and only those sources which produce “income from an active business” are to be considered with respect to the small business deduction. The appellant, as mentioned, contends that the profit arising from the sale of shares in 1973 should be considered as part of the income of the appellant within the ambit of section 125 so that it be considered as income from an active business carried on by the appellant in Canada. ... Accepting the proposition that a corporation may have a source of income which is considered to be such a source that it is an active business and so entitled to the small business deduction; may it have another source or sources of income which are such that they are not from an active business and so the total income of the corporation is not entitled to the so-called “small business deduction” but, rather, only the portion of its total business income which can be considered from an active business is entitled to the small business deduction? ...

The amounts received by Edward Djoboulian from Egypt were considered by the Board and calculated in arriving at his net worth figure. Having already been considered in Edward Djoboulian’s net worth figure, these amounts cannot now be used again to explain the appellant’s capital assets as at December 31, 1973. ...

The Board must decide whether it can be considered individually or whether it must be considered together with all the other immoveables. 3.2.5. ... Several other cases were also cited by the parties and considered by the Board. ... Shed No 2 is considered included in Class 3. Appeal allowed in part. ...

With respect to Lot 16 he considered it much superior to the subject property. ... The third parcel he considered on Elmwood Drive was sold for $12,000, or $240 per acre. While it had services such as highway, telephone and electricity, he considered it inferior to the Price property. ...