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The relevant provision of the Income Tax Act is as follows: 118.4(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 (i) perceiving, thinking and remembering, (ii) feeding and dressing oneself, (iii) speaking so as to be understood, in a quiet setting, by another person familiar with the individual, (iv) hearing so as to understand, in a quiet setting, another person familiar with the individual, (v) eliminating (bowel or bladder functions), or (vi) walking; and (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. ... It must be remembered that Parliament chose, in paragraph 118.4(1)(d), to exclude other activities, including working, housekeeping, a social or recreational activity from being considered as a basic activity of daily living. ...

The Minister of National Revenue considered that these expenditures were personal or living expenses. ... The following criteria should be considered: the profit and loss experience in past years, the taxpayer’s training, the taxpayer’s intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ...

The reasons for the decision include the second review report provided to the Applicant and the notepad entries made by CRA officers throughout the course of review: Aryan v Canada (Attorney General), 2022 FC 139 [Aryan] at para 22. [13] The Officer considered the Applicant’s submissions, the CRA’s guidelines for determining CRB eligibility, the other officers’ entries on the Applicant’s case, information gathered during his telephone calls with the Applicant, and the Applicant’s relevant financial information including her income statements. ... Absent exceptional circumstances, reviewing courts must not interfere with the decision-maker’s factual findings and cannot reweigh and reassess evidence considered by the decision-maker: Vavilov at para 125. ...

It is to be remarked however that this statement was not. necessary for the decision of the case, for the betting in question was not considered as unlawful, although of course no action would have lain to recover the bets. ... The learned trial Judge also considered that the appellant should not be heard to invoke ‘‘his own turpitude to claim indemnity from paying taxes and to be placed in a better position than if he were an honest and legal trader. ’ This appeal, however, must be decided solely on the case stated by the parties. ...

The company, under the provisions of sec. 20, retains its corporate state until its affairs are wound up, and under sec. 69 all claims against the company, present or future, must be considered. ... The liquidator is however mentioned in some clauses in the Act, establishing by necessary implication that he is considered as a person accessible to the arm of the law under the Act. ...

This to my mind indicates that the broker is not to be considered as the seller but merely the agent for bringing about the sale. ... No doubt amendments at times are made out of abundance of caution but they cannot be considered by the Courts. ...

It must be admitted that, in the general acceptation, one who acquires land under an agreement for its purchase and takes possession thereof is considered to be the owner. ... Vermilion Hills R.M. [1916] 2 A.C. 569, it was held that a tax might be imposed on a person in respect to the interest acquired by him in Crown lands although the lands were exempt and that the assessment should be considered limited to that interest. ...

Where a husband transfers property to his wife, or vice versa, the husband or the wife, as the case may be, shall nevertheless be liable to be taxed on the income derived from such property or from property substituted therefor as if such transfer had not been made.” (11) The transfer or payment made by the said Molson to his said wife, as evidenced by the Deed of the 23rd of March, 1925, was not intended to be and was not in fact considered as a transfer to evade taxation within the contemplation of the Amending Statutes passed over fifteen months later. ... The said donation was accepted by the future wife as being in lieu of her community and dower rights and the agreements in regard thereto were not in fact and could not in any way be affected by The Income War Tax Act, 1917, or any of the amendments thereto. (13) In like manner, the fulfilment of the contractual obligations assumed by Molson in the said Contract of Marriage, as evidenced by the Deed of Conveyance of the 23rd of March, 1925, was also legal and cannot be considered as, and in fact was not, a transfer to evade taxation within the meaning of the Amending Statutes of June, 1926 (R.S.C., 1927, Cap. 97, Section 32), and the appellant is entitled to have it so declared/ ‘ On March 2, 1935, the Minister replied denying the allegations of the notice of dissatisfaction and confirming the assessments. ...

This amount was arrived at in the following manner: Net profit of Interprovincial $102,473.09 Net profit of North American 17,964.08 $120,437.17 Net loss of Intercolonial- 44,441,78 Net profit 75,995.39 50 per cent of Net profit 37,997.69 The Commissioner of Income Tax allowed the net profit of North American to be considered as a gain or profit of Interprovincial but refused to allow as a deduction the loss sustained by Intercolonial. ... By agreement Intercolonial was not to deal in other securities, and the debentures were apparently considered a form of security for the 0,000 shares of the stock of James Richardson & Sons Ld. ...

The stipulation in the contract relied upon by counsel for the Minister of Finance as to retention of title and property in the inventoried goods by the Firestone Company, obligation on the Distributor to insure them in the Firestone Company’s name and compulsion to sell them at a price fixed by the Firestone Company were all present in the contract considered in the case of John Deere Plow Co. v. ... Paragraph 6 of the contract must be considered in conhection with para. 2 of the Schedule. ...