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The obvious question in this case is: should the appellant be considered as subject to tax under the appropriate provisions of the Act on the ground that her husband was active in real estate, even though the evidence clearly indicates that most of his activities were unknown to the appellant and she had little real interest in his business affairs? ...

In my opinion, because of the course of conduct of the appellant company and that of its main shareholder, the gain under discussion should be considered taxable and, consequently, the appeal is dismissed. ...

It does not appear that the issue we are concerned with was raised or considered. ...

As such, he argues (for the first time) that the Payment should be considered an advance on commissions to be earned over a seven-year period, and therefore a portion of the Payment should be treated as a reserve and assessed as income in later years. ...

To engage the services of persons, professional or others, for performing any services considered as incidental to the powers of the company. 6. ...

In that case the Minister contended that money borrowed for redemption of shares was certainly not to be considered as capital borrowed for the purpose of earning money, and that therefore the interest payable thereon could not be treated as a deductible expense. ...

The appellant contends that the transaction should be considered as a whole and that the deductions which were permissible to him, as a resident of Canada, should also be permissible as a non-resident. ...

Beardmore, on the other hand, claims that the amounts of $20 a month paid to her were not for her maintenance but were the reimbursement by her husband of advances made by her toward the payment of common debts and, as such, cannot be considered as income in her hands. 11 In attempting to determine the deductibility or otherwise of the $20 monthly payment made by Gordon R. ...

For the 1991 and following taxation years that subsection reads as follows: (1) For the purposes of subsection 6(16), sections 118.2 and 118.3 and this subsection, (a) an impairment is prolonged where it has lasted, or may reasonably be expected to last, for a continuous period of at least 12 months; (b) an individual's ability to perform a basic activity of daily living is markedly restricted only where all or substantially all of the time, even with therapy and the use of appropriate devices and medication, the individual is blind or is unable (or requires an inordinate amount of time) to perform a basic activity of daily living; (c) a basic activity of daily living in relation to an individual means (iv) hearing so as to understand, in a quiet setting, another person familiar with the individual, (d) for greater certainty, no other activity, including working, housekeeping or a social or recreational activity, shall be considered as a basic activity of daily living. ...

., the giving must be regarded as not having been perfected and the sailboat must be considered to have continued at all material times to be part of the patrimony of the judgment debtor, and therefore subject to seizure on December 7, 1996, for a tax debt certified in an amount of over $14.000. ...