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The trial judge concluded that they had a close personal relationship. [9] The Tax Court also considered the evidence concerning Ms. ...

[emphasis added] [12] The paragraphs that followed, including paragraph 81, described factors that I would have considered. [13] At paragraph 81, I stated that there was extensive evidence regarding how the Appellant priced its policies. ...

Having regard to that standard, and having carefully reviewed the record and considered the appellant’s submissions, we see no error warranting our intervention. ...

We find these submissions to be without merit. [5] The Tax Court judge considered whether rule 170.1 applied. ...

Minister of National Revenue, [1978] CTC 2357, [1978] DTC 1271 Delmer E Taylor:—This is an appeal against income tax assessments in which the Minister of National Revenue increased the taxable income of the appellant by $5,649 and $13,182 for the years 1972 and 1973 respectively, the amounts being considered income and not capital receipts. ...

The appellant, Mr Miller states, was cognizant of the fact it had the right to specific performance for the remainder of the term of the licences, but also considered the fact that the logging and lumbering economy at that time was sagging, and it might well be stuck with a worthless judgment. ...

His “start up” costs should be considered valid, and the care and attention required by his animals was detailed for the Board. ...

The appellant, on the other hand, claims that the gain was capital in nature and considered it as such in his income tax return. ...

The amount paid was considered as income according to subsections 5(1) and 8(1) of the old Act. ...

For these reasons the appeal is allowed on the basis that deductions should be considered for each of the appellant’s children who meet th requirements of paragraph 109(1)(d) of the Act if this has not already been done, and the matter is referred back to the respondent for reconsideration and reassessment accordingly. ...