Search - considered

Counsel said that the acquisition of the property in this case should not be on capital account but rather considered as inventory and on income account. ...

The only question that had to be considered was whether the amount claimed by the appellant was reasonable in the circumstances since the Income Tax Act does not require that receipts be filed in support of an expense. ...

Where the property has not been put to any use for an extended period of time after it was acquired or, if used, not for its intended use, the property may still be considered acquired "to be used" or “for use” if the taxpayer can show sound business reasons as to why it is not being used as originally intended, e.g., if it would be economically unsound to carry out the original intention because of unforeseen or changed circumstances. ...

On the evidence that was before me, I can only conclude that the appellant's activities do not meet the threshold required for him to be considered as “carrying on a business”. ...

From the appellant's subjective viewpoint, certainly the use and enjoyment by her of the space afforded by the adjacent Lot 77 is a matter to be considered. ...

Accordingly, even if the execution of the quit claim deed amounted to a transfer, which need not be considered, the value of the Taxpayer's interest in the residence was nil. ...

In determining whether such commitments were made, all relevant facts and evidence will be considered including: formal documentation of the commitment; the nature of the original financing which should have the characteristics of usual interim financing, e.g. demand bank loan; the time lag between the date of the original financing and the date of the loan; and, the reasons why the original financing was not by the lender. ...

Commissioners of Income Tax for Trinidad and Tobago, [1945] A.C. 1, the Privy Council considered the question whether there was a “transmission” of income derived from a source within the colony when a company within that colony agreed to set off a debt owing by a non-resident shareholder to the company for goods supplied by it against the amount of a dividend declared by the company on its shares. ...

Such losses are only one of several factors that must be considered in arriving at a determination that a business activity did or did not offer a reasonable expectation of profit. ...

He considered his own operation of buying, training and racing horses to be a business. ...