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It is not and has not been disputed that the fees were incurred following the filing of the Notice of Appeal and related solely to the provision of information and material by Rennie & Company to enable the Appellant to put forward his position at trial, and the Registrar so found. [6] The issue posed by the Registrar was “can the accountant’s fees be considered an ‘essential’ disbursement or are they fees for the type of services normally provided by counsel simply recharacterized as a disbursement”. ...

Analysis and Decision [13] Three recent decisions of the Federal Court of Appeal, namely Tonn, 96 DTC 6001; Mastri, 97 DTC 5420 and Mohammad, 97 DTC 5503 have analyzed and distilled the factors to be considered in determining whether a taxpayer can be said to have a reasonable expectation of profit from a rental operation. [13] These decisions, in essence, say that when there is a personal element involved, i.e., in this case the renting of the property to relatives, the taxpayer has a stronger burden of proof to establish that he or she had a reasonable expectation of profit. ...

(e) Finally there must be considered-- and this is the most difficult principle to formulate-- the criteria to be employed in forming the judgement whether the mental impairment is of such severity that the person is entitled to the credit.... ...

Towards this end, the Appellant must show the Court whether he considered the amount to be uncollectible and unrecoverable. [14] For the period January 1, 1991 to December 31, 1991, the Appellant reported income of $148,250.00. ...

., 86 DTC 1542, this Court determined that clothing could be considered to be "supplies" but could not be "consumed". ...

* An inordinate amount of time is considered to be a time so great that your patient would not perform the activity if it was not necessary. ...

Those years will have to be considered on their own. [17] The appeal for 1994 is dismissed. ...

In instances where the driver's means of financial support is [sic] inextricably bound up with the respondent we are of the view that he cannot be considered an independent contractor. [4] The Appellant was retained by the Gallery under two essentially identical agreements the first dated January 9, 1995 and the second dated April 18, 1995. ...

At pages 1198-99, he said that equipment differs from supplies and that even if it is assumed that equipment can be considered supplies under this statutory provision, it must be proved that the equipment wore out from use during the year. ...

This is more so when the adjusted figures below are considered. (b)      The mortgage had to be increased for the unforeseen reasons discussed above. ...