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He had to keep up with modern techniques and technical developments in chemistry and indicated that in the Public Service, so-called professional societies are considered desirable qualifications. ...

It is laid down thus in City Discount Co v McLean by Blackburn J (LR 9 CP 700), and expressed by Lord Selborne in Re Sherry (25 Ch D 702), in somewhat similar language: “It has been considered a general rule since Clayton’s case that when a debtor makes a payment he may appropriate it to any debt he pleases and the creditor must apply it accordingly. ...

At least in part, that difference of opinion related to whether the term misrepresentation should, under the new Act, be considered as innocent misrepresentation or whether something of the nature of wilfulness (misrepresentation on a level in the scale higher than that which was required of the Minister) before reopening a statute-barred year. ... Mr Appleby’s objections relating to the fact that the Bevan reassessment accepted certain perspectives and assertions, which had been rejected in the Hobson reassessement, are not considered substantive. ... The Board points out that the Frenchlanguage version of the same two sections uses the identical French word “négligence”, and therefore, for purposes of this decision, the Board holds that the legislators did not intend any distinction to be made, and the word “neglect” is to be considered as synonymous with “negligence” under subsections 152(4) and (5) of the Act. ...

The appellant said that, at that time in the political life of Quebec, political contributions were considered an insurance for obtaining or retaining contracts. ... However, if an apartment building is built to be resold, the resulting profit will probably be considered business income, and the transaction might also be classed as an isolated act of a commercial nature. ... If evidence to this effect had been submitted, the Board would have considered that the said interest was deductible. ...

The privilege, granted by the seller of a business to the purchaser, of trading as his recognized successor; the possession of a ready formed “connexion” of customers, considered as an element in the saleable value of a business, additional to the value of the plant, stock-in-trade, book-debts, etc. ... On the advice of his advisers, the appellant reduced this amount to $24,000, which was considered more normal. ... If so, it must be regarded as part of the general business goodwill which is considered below. 7.5 If Mr Couture had died at the beginning of February 1969, would the organization then existing, that is the contracts with manufacturers, have contained a source of general business goodwill? ...

Mr Paquet used the parity method. 3.03.2.5 The witness Jacques Giguere, the respondent’s appraiser, considered that the fair market value of this land on December 17, 1970 was $352,000, or $1.15 a square foot (Exhibit 1-1 and testimony of Jacques Giguere on March 21, 1978, pp 101 to 186). ... The question then becomes whether the profits resulting from the transactions at issue are capital gains or business profits. 7.02.2 Capital gain or business profit 7.02.2.1 Points to be considered The chief points to be considered in determining whether the profits resulting from a transaction constitute capital gains or business income have long been established by precedent: the nature of the property; the intent at the time of purchase; the number and frequency of similar transactions; the taxpayer’s activities; the circumstances of the sale; the presumption that a company is engaged in commerce. 7.02.3 The nature of the property and the presumption that a company is engaged in commerce Certain property, such as comestibles (fruits, vegetables and so on), building materials (iron, cement and so on) or items for personal or industrial use (tools, cleaner and so on) are by nature commercial. ... The rule in Fraser (p 5226) was considered by the Exchequer Court in Shipp et al v MNR, 67 DTC 5222. ...

At the same time, it had been considered prudent for the Company to acquire and hold certain property sites for future churches in many parts of Canada. ... Whatever its activities in earlier years, the metamorphosis must be considered complete for the years under review and the Company joined the business world for purposes of the Income Tax Act. ...

As there was a material disruption to the company the Earnings Method is not considered appropriate and the Liquidation Method has been used. ... As additional costs and accumulated depreciation were roughly the same over the period a December 31, 1971 net book value is considered to be the average or $15,583 The (sic) would result in an increase in value of $146,370 4. ...

There are professions today which nobody would have considered to be professions in times past. Our forefathers restricted the professions to a very small number: the work of the surgeon used to be carried on by the barber, whom nobody would have considered a professional man. ...

That may be renewed for another two (2) years and then a final one (1) year contract would be given, during which time tenure would be considered and if tenure is granted, then the person remains on the faculty until there may be some cause for dismissal. ... In the instant case control existed to whatever degree considered adequate and advisable by the University, over its full-time staff, and the evidence does not support the view that it was further diluted or, as alleged, eliminated entirely to accommodate the particular circumstances associated with part-time staff. ...