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In 1979 the appellant as a businessman and in his judgment considered, and reasonably so, that the debt owing by the Company was uncollectable. ...

I have considered the authorities advanced by both the appellant and the respondent, as well as other cases, and without going into details, I have come to the conclusion that the taxpayer did not look to farming in the racing and breeding of horses for his livelihood, despite the hours and efforts he devoted to this endeavour. ...

Thorson, P in the Exchequer Court of Canada decision of W A Sheaffer Pen Company of Canada Limited v MNR, [1953] CTC 345; 53 DTC 1223, said at 350 (DTC 1226): It is thus a cardinal rule of interpretation that the context in which a word in the Act appears must always be considered in order to ascertain its true meaning. ...

Conversely, such periodicals and other items which directly related to reducing or controlling operating cost of the apartment buildings, or of procedures for increasing the rents therefrom would be in all likelihood appropriately considered as costs on operating account. ...

In the case Spur Oil v The Queen (Court file T-3596-76), The Hounourable Mr Justice Cattanach in his Reasons for Judgment dated June 8, 1982, considered the matter of taxable fees allowable to counsel and to expert witnesses at trial, and their respective responsibilities. ...

I readily agree that there are substantial difficulties in the way for Mrs Perlman to establish that her money-lending activity could be considered a “busi- ness”. ...

It seemed quite clear that there was no provision for the specific deduction of this amount, but the Court reserved the decision, because two interesting points arose during the hearing — first, whether the payment at issue could be considered in some way a contribution towards a revenue-producing property — the right to a pension, and therefore deductible; the second, the significance of the phrase in paragraph 146(5.2)(c) — “any similar plan of a country other than Canada’’. ...

With this guidance and the factor suggested to be considered in the case of Guy Rajotte v The Minister, reported in [1979] CTC 2555; 79 DTC 436, I have applied the facts as put forth in evidence. ...

Counsel for the plaintiffs delivered a very persuasive argument on the conditions necessary for the establishment of a trust, and referred in particular to the case of Waselenko and Waselenko v Touche Ross Ltd, et al, [1983] 2 WWR 352, which I have considered quite carefully. ...

The situation, in my view, is exactly that as previously considered in Cooper Laboratories Ltd v The Deputy Minister of National Revenue for Customs and Excise (unreported Tariff Board Appeal No 1364, November 8, 1979), wherein the Board states: The evidence showed that the Packer’s Pine Tar Shampoo and Soap are sold and represented for use in the treatment and mitigation of skin and scalp troubles. ...