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This, in my humble opinion, was the exercise engaged in by the TCC. [6]    The lack of organizational structure in the appellants' business was not the sole evidence considered by the TCC to demonstrate the absence of carrying on an active business. ...

The appellant in his argument said that many Western farmers considered such advances under the said Act as interest-free loans and that “Good Farming”, a farming magazine had used this terminology in a number of its articles which had indicated to him and probably to many others that advance payments could properly be held in suspense until the year of actual delivery of grain. ...

In my view, this recitation of the applicable law is that in Ludco and far from over-emphasizing the wife’s subjective purpose, the Judge considered and gave weight to a number of objective manifestations of the purpose for which the shares were purchased:   •                      There was no evidence that the family corporation ever paid dividends prior to 1999 (reasons, paragraph 32) ...

.:   While in the sense identified by the majority, subsection 160(1) may be considered a harsh collection remedy, it is also narrowly targeted. ...

The $60,000 here in question should therefore be considered as being the price that the appellant had to pay to obtain a new long-term contract from the Quebec Autoroute Authority. ...

(f)        where all or substantially all of the non-resident person's income for the year is included in computing the non-resident person's taxable income earned in Canada for the year, such of the other deductions permitted for the purpose of computing taxable income as may reasonably be considered wholly applicable. ...

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. ...

At paragraph 18, the Federal Court of Appeal said: 18         Conversely, the expenses incurred by the payer of support (either to prevent it from being established or increased, or to decrease or terminate it) cannot be considered to have been incurred for the purpose of earning income, and the courts have never recognized any right to the deduction of these expenditures (see, for example, Bayer, supra). [7]      The reasoning is that while the recipient of support payments may be incurring the cost of receiving income, the same cannot be said of the payor. [8]      Mr. ...

But unfortunately Mr Miconi has been unable to satisfy this Court that the assessments are in error except to the extent that Revenue Canada has considered Mr Miconi the owner of both properties. ...

The plaintiff received a notice of reassessment, dated March 18, 1988, for the taxation year 1985 indicating that the money lent out by Allstate was considered to be funds or property of Meridian Seed Farm Ltd. that was appropriated to a taxpayer in that year and which, by virtue of paragraph 15(1)(b) of the Income Tax Act, should have been included in computing his income. ...