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Information Circulars IC 92‑1, IC 92‑2 and IC 92‑3, all of which are dated March 18, 1992, were considered by Mr.  ... Watson of the TCC, who considered the appeal valid. It appears that the TCC’s lack of jurisdiction to review a negative decision by the Minister concerning the cancellation of interest was not raised or discussed at that time. ... Lepage stated that she had considered the fairness request based on the criteria set out in Circulars 92‑1, 92‑2 and 92‑3. ...

The cases cited by either side herein have all been fully considered save a number of American decisions and others that would not bind us. ... Having considered the question and seeing no point made of it by respondent, I conclude that, the amount involved far exceeding the $2,000 limit, the appeal lies. ... They were made in cases where the acts considered were done in the exercise, or assumed exercise, of judicial, as distinguished from any other authority. ...

But, how do we know that the provision was not repealed because it was considered useless? ... He also urged in alternative that if the payment is considered as income, it should be treated as income for the taxation year 1962 rather than 1963. ... It is thus clear that the matter of goodwill was considered in the drafting of the partnership agreement. ...

The Board, acting under s. 11(3) of its above-mentioned Act, considered the required statutory declaration in support of the appellant’s claim to be a refugee under the Act and concluded, without permitting the appellant to give additional evidence or to make [Page 643] additional submissions, that the appeal should be refused and the order of deportation executed as soon as practicable. ... She says she came to Canada when she considered her daughters old enough to look after themselves. ... This enactment was considered by this Court in Muzak Corporation v. Composers, Authors and Publishers Association of Canada Ltd. [17] The decision from which leave to appeal had been granted was an “order” for service out of the jurisdiction. ...

  [23] It is extremely doubtful that a simple licence could itself be considered property at common law.  ... To the extent the regulatory cases are considered relevant here they do not assist the appellants, in my opinion.  ... Parliament unambiguously signalled an intention to sweep up a variety of assets of the bankrupt not normally considered “property” at common law.  ...

Specifically, the issue for the parties was whether the complaint may be considered as vexatious because this Court and the Federal Court of Appeal had already dealt with the human rights issue. [14]            On November 9, 2015, the Applicant submitted a letter to the Commission in response to the 40/41 Report [Response Letter]. ... It also considered whether the Minister’s decision under section 63 of the Income Tax Act was reasonable. ... That finding is supported by the record; the Applicant’s claim had already been considered both by this Court and by the Federal Court of Appeal. ...

Consequently, the Minister’s Delegate’s analysis with respect to the alleged CRA error was reasonable. (3)                Delay on the part of the CRA [35]            The respondent submits that the Minister’s Delegate considered Mr. ... The respondent contends that this analysis was reasonable as the Minister’s Delegate considered the timelines between the audit and objection stages, and found they were within the three-year period provided for by the Act. ... Easton’s contention that the Minister’s Delegate should have or could have accessed his entire file, the evidence he submitted that was not before the Minister’s Delegate will not be considered. ...

Where the nature of a taxpayer’s activities contains elements that suggest that the activities could be considered a hobby or other personal pursuit, but the activities are undertaken in a sufficiently commercial manner, the venture will be considered a source of income for the purposes of the Act (Stewart, paragraph 52). [38]         The “pursuit of profit” source test will only require analysis in situations where there is some personal or hobby element to the activity in question. ... R., 2011 TCC 262, considered that risk minimization is also a factor to be considered. ... If these expenditures were in fact spent on gifts for prospective clients, they were completely unreasonable when considered in the light of his revenue. ...

It appears from the reasons that the marked restriction was considered to be with respect to the necessary mental functions and that the vital function for which the therapy was necessary to sustain was brain function. [22]          In deciding the sole issue of whether the 14‑hour weekly therapy requirements were met, Justice Jorré concluded: 1.       ... This activity cannot be considered in determining the weekly average time. 22.       ... An impairment that limits what the person is capable of processing as nutrition to fuel the body without causing severe and permanent bodily damage might well also be considered in giving a humane, compassionate and commonsense interpretation and application of this DTC provision. [68]          The appeal is allowed. ...

Canada, [1996] 2 C.T.C. 1, relied upon by the Respondent, where it considered a director’s liability in the context of the bankruptcy of the corporation. ... These circumstances must be taken into account, but must be considered against an objective "reasonably prudent person" standard. b.   ... Corrective actions must also be considered. [105]   The Appellant refers to the numerous meetings that took place between Ms.  ...