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Therefore, it was Access Cash’s cash that was loaded into the ATMs. [12] In determining who operated the ATMs, the Tax Court Judge considered a number of factors. [13] He found that Access Cash connected the ATMs to the Interac network and was responsible for loading the cassettes (that contained the cash) into the ATMs. ... [footnote reference omitted] [19] The Tax Court Judge found that the cardholders paid the surcharge fee to Access Cash for services provided by Access Cash and that Access Cash paid River Cree for supplies made outside the series of supplies that allowed the cardholders to withdraw money from their bank accounts by using the ATMs. [20] The Tax Court Judge then considered whether there was a single compound supply or multiple supplies of separate goods and services made by River Cree to Access Cash. ... Joint Venture [29] The Tax Court Judge considered River Cree’s argument that it was in a joint venture with Access Cash. ...

The Applicant does not dispute that the Officer considered all of her documents, including her additional invoices and cheques. ... Not all errors or concerns about a decision will warrant intervention. [50] The Applicant accepts that the Officer considered all of her evidence to conclude that she had made at least $5,000 gross self-employment income. ... Having considered the factors listed in sub rule 400(3) of the Rules, as well as the calculation made by the parties, and all other circumstances of this case, I find that no award for costs is warranted in this matter. [64] Both parties argued in favour of the costs they should be awarded. ...

The very next sentence in Ikea states that there is no link to a capital purpose. [30] The necessary linkage to something on revenue account is also made clear at paragraph 30 of Ikea: [30] As for the second contention, Ikea argued that if the payment were to be characterized as consideration for its continued obligation to carry on business in the premises during the term of the lease, it should be considered a capital receipt because such a payment goes to the “structure of the business”. ... It should have considered whether the Fees were linked to something on revenue account. ... They include amounts that “can reasonably be considered to have been received” (1) as a reimbursement in respect of the cost of property or an outlay or expense, or (2) as an inducement. ...

The objects stated in the Memorandum of Association of the appellant are to be considered. ... As to the Barnsdall lease it was agreed that it had been made by Minerals at the request of Leaseholds and as between the parties was to be considered as a sublease oranted by Leaseholds under a further lease to be entered into on that date. ... The other considerations for the granting of the new lease are not relevant to the matters to be considered. ...

Thomas Collins considered the Davis farm good value for the purchase price in that it had a potential compared to Lavington which was suburbanized. ... The appellant Thomas J Collins says that at the time of the purchase of the Davis range land, he considered it good and gave as his reason for buying this land, so far away from his Lavington Stock Farm, that he wanted a large farm unit. ... Although he was not dealing in what is normally considered to be a subject of commerce such as commodities, the transactions from its very inception was purely speculative in character and was, in our opinion, as a matter of law, a venture in the nature of trade. ...

" Since he did not have occasion to make such adverse reference, it is to be assumed that he considered all of the documentary evidence both credible and relevant. ... Each stage was considered to be a distinct profit centre. The profits ascribed to production and transportation were the difference between the cost and the fair market value of the crude delivered to Saint John. ... Neither considered that it had a deal until the contracts were signed. ...

., were capital costs and that therefore they should be considered as capital costs within the meaning of sec. 90. ... The section was further considered by the Supreme Court of Canada in the case of Minister of National Revenue v. ... It was held by Atkinson, J.: "Held: (1) an expense properly and reasonably incurred in the final ascertainment of profits might properly be considered as an outlay in order to earn profits and not an outlay of profits, certainly not of ascertained profits, as the profits were at all times subject to that outstanding expense. ...

MeCool considered it advisable to operate the said Limits (which will hereafter be referred to as ‘‘the Booth Limits’’) and his other assets through the medium of an incorporated com- pany. ... Subsequently, the directors considered these matters, approved of the acquisition of his assets on the basis of that agreement and passed a by-law authorizing the execution of the agreement above referred to and dated November 28, 1941. ... If cost to the taxpayer were the only matter to be considered, the statutory discretion of the Minister would be seriously interfered with and grave abuses could quite easily result. ...

However, decision-makers are presumed to have considered all evidence presented to them unless the contrary is shown (Perinpanayagam at para 35). ... The Second Reviewer did not render a decision lacking specificity to the Applicant’s situation, as the Second Reviewer summarized the Applicant’s submissions and considered the relevant factual matrix in determining whether the Applicant qualified for relief under section 207.06 of the ITA. ... However, the Second Reviewer considered when the Applicant withdrew the excess contribution in determining whether the Applicant withdrew it without delay. ...

When all of the eligibility requirements are met and a specified member of a qualifying group elects, at any time on or after January 1, 2015, jointly with another specified member of the group, certain taxable supplies made between them are considered to have been made for no consideration.   ... When all of the eligibility requirements continue to be met and parties to an existing election with an effective date before January 1, 2015, that is still in effect on January 1, 2015, continue to elect jointly with each other, certain taxable supplies made between them after 2014 are considered to have been made for no consideration. … Parties to an existing election with an effective date before January 1, 2015, that is still in effect on January 1, 2015, are also required to file the election form.   ... The record also shows that he changed his view once all of the facts were considered. [31]   The decision under review was made by the Minister’s Delegate, the Assistant Director, Audit on September 11, 2018, and I am satisfied that the Denso Companies had sufficient information to know the CRA’s concerns and the case it had to meet.   ...