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Had she been ninety or crippled, she might have been considered a dependant under the Act, but no evidence has been offered other than the mere fact of age. ... The answer of the appellant may be summarized that they were dependent for support on him as the son (or son-in-law) since they did not have sufficient financial resources to maintain themselves properly; and because they are quite old (ranging 68 and 77 years), they must be considered infirm. ...

Point at Issue The issue is whether the appellant’s proceeds from the sale of two service stations to its lessee, Texaco, with an option to purchase, should be considered as capital gains or as business profits. ... He had not considered this. 3.22 On January 31, 1973, pursuant to a letter from the appellant stating that it did not wish to renew the St-Félicien contract, Texaco Canada Limited (Exhibit A-9) decided to exercise the purchase option clause and purchase the station for $46,000. 3.23 The notarized contract relative to this sale of the St-Félicien station was entered into on April 10, 1973 (Exhibit A-10). 3.24 Mr Verreault did not personally attend to the St-Félicien station. ...

I cannot see how these expenses can be considered in the same category as the expenses which were under consideration in the M P Drilling case. ... Since I cannot delineate in quantum between the housekeeping expenses and the incorporating expenses as mentioned previously, all shall be considered as one with the result that judgment shall go dismissing the appeal. ...

The appellant’s submission, briefly stated, is that the term “warrants” for tax purposes should be considered in the same light as shares. ... He had seen Exhibit A-2 and decided with his partners in 1971, 1972 and 1973 that warrants could be considered in the same investment category as common shares and on the recommendation of Sceptre, the appellant purchased the warrants. ...

He made numerous calculations to his recapitalization of sales and earnings to “normalize” them and,- after arriving at what he considered in his opinion to be the weighted average normalized net income of $38,820, he capitalized it at 25% and valued all the shares of the company at $155,280 at December 29,,1971—or a share value of $77.64. ... All things considered, I am of the view that the value of the shares on Valuation Day would be more reasonably stated to be $55 per share considering all the factors which both experts put forth. ...

The Parties hereto agree that the clients or customers of the Vendor and their files as set out in Schedule “A” attached hereto shall remain the sole and exclusive property of the Vendor and are not to be considered as part of this transaction and shall be serviced by the Vendor and he shall be entitled to all commissions paid thereon. ... The result is, having considered the facts of this case, and having read the Cumberland Investments Limited case several times, I have concluded that the expenditure made by Mr Moreau in 1973 in connection with his acquisition from Mr Bellehumeur was an outlay within the meaning of paragraph 18(1)(b) of the Income Tax Act, SC 1970-71-72, c 63, as amended, and not within paragraph 18(1)(a). ...

A secretary, provided by the NBTF, shall be a non-voting member. 36.04 A teacher granted sabbatical leave shall be guaranteed the same or equivalent position on returning to that School District. 36.05 Subject to 36.06, teachers on sabbatical leave are considered to be under full contract with the Board of School Trustees and therefore retain full status and receive all the benefits that any other teacher would receive. 36.06 The sick leave provisions of this Agreement shall not apply to those on sabbatical leave; however, those teachers on sabbatical leave shall not lose their accumulated sick leave. 36.07 No teacher serving on the Sabbatical Leave Committee shall lose salary, sick leave benefits or pension benefits due to an absence or absenses from school under this Article. ... The appellant’s application was considered along with others and subsequently he was orally advised by Mr Kingett (a voting member of the Sabbatical Leave Committee) that he was awarded Sabbatical leave starting at the end of the 1973-74 academic year. ...

It is proposed to reassess your return to reduce your total Medical expenses from $867.57 to $713.30 as lodging, meals and non-prescription drugs are not considered to be medical expenses. ... Thank you.-5 August 9, 1974 Your claim for meals and lodging is not considered a deductible expense according to Paragraph 110(1)(c) of the Income Tax Act, which sets out allowable medical expenses. ...

The Exchequer Court upheld the judgment of the Tax Appeal Board by deciding that the sum of $33,200 ($34,600 minus $1,400, the surrender value of the policy) should be considered taxable in the Same manner as salaries. The payment of the lump sum was in fact considered to be provided for in the employment contract since Mr Moss’ right to purchase the shares for 90% of their value was provided for in the employment contract. ...

The respondent considered them to be associated and taxed them accordingly. ... The Board concludes that the group composed of the Perron sisters and their mother should be considered as the one controlling the company, thus eliminating the other two groups. 6.1.2 Second Condition Is each member of one of the related groups related to all the members of the other related group? ...