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Until 1988, the Appellant purchased all of its asphalt from third-party suppliers and as a result considered itself at their mercy, both in terms of price and availability, since they were in actual fact competitors. In or about 1987, the Appellant considered its options. It knew how much asphalt it required each year and was able to estimate the cost of acquiring a plant to provide for its needs. ...

The question therefore is simply this: Can the damages awards in question properly be considered part of the "cost to the taxpayer" of the Hidrogas shares? ... As I see it, the damages awards could not be considered part of the price the deceased had to pay to obtain those shares by any stretch of the imagination. ...

So there is no way that that could not be considered. [9] The appellant did not dispose of T.K.T.'s shares in the years in question. ... Before that decision I believe that in a way similar to shares, land was considered to be purchased or for resale or for a capital investment, not for operational purposes. ...

The Supreme Court of Canada points out that even where there is a personal pursuit, if it is undertaken in a sufficiently commercial manner, the venture will be considered a source of income. ... It goes on to cite the objective factors to be considered as: 1.         ...

This issue does not appear to have been previously considered by the Court with respect to either late filed objections or appeals. ... This case and this last issue are significantly different than the issues of awareness and understanding of an assessment, and of discoverability, considered by the Federal Court of Appeal in the case of   H. ...

., supra, the Tax Appeal Board ("Board") considered the proper way to compute the proceeds of disposition in order to determine recapture of capital cost allowance. ... Demers cannot be considered, however, as confirming in any general way that the fair market value of the non-monetary consideration must be determined in order to determine the proceeds of a disposition appropriately. ...

As a general rule, the on-site fabrication, installation and erection of machinery and equipment, regardless of size, is not considered to be construction, unless it constitutes a component part of a building or structure (e.g.: heating system, air- conditioning equipment, sprinkler system, plumbing, wiring, etc.). ... Paragraph 3 is to the following effect: As a general rule, the on-site fabrication, installation and erection of machinery and equipment, regardless of size, is not considered to be construction, unless it constitutes a component part of a building or structure (e.g. — heating system, air- conditioning equipment, sprinkler system, plumbing, wiring, etc.). ...

In the event that it should be considered that the licences are property in themselves and not an element or component part of the vehicles, he then contends, as an alternative, that the licences fall within Class 14 of Schedule B as property that is a licence for a limited period in respect of property. ... Section 20(6) (g) of the Income Tax Act provides: 20. (6) For the purpose of this section and regulations made under paragraph (a) of subsection (1) of section 11, the following rules apply: (g) where an amount can reasonably be regarded as being in part the consideration for disposition of depreciable property of a taxpayer of a prescribed class and as being in part consideration for something else, the part of the amount that can reasonably be regarded as being the consideration for such disposition shall be deemed to be the proceeds of disposition of depreciable property of that class irrespective of the form or legal effect of the contract or agreement; and the person to whom the depreciable property was disposed of shall be deemed to have acquired the property at a capital cost to him equal to the same part of that amount; In assessing the appellant, the Minister considered that an amount of $18,590 of the purchase price could be reasonably regarded the consideration for the 14 taxicabs as automobiles, being depreciable property with Class 10 of Schedule B to the Income Tax Regulations and subject to a capital cost allowance accordingly. ...

Canaport reviewed and considered the recommendations set out in Exhibit D and, on or about August 21, 1984, issued to four engineering firms requests for quotations for a study of the repair or replacement of the Sealine. ... On the basis of the 1985 RTD Report and the reports from Hudson and Wescan, Canaport, together with the Engineering Department of Irving Oil, considered the available options for remedying the large areas of corrosion in the Sealine. ...

All payments on account of capital of any mortgages shall be considered as expenses in calculating the Net Profit. b) Not to be considered as expenses in determining the Net Profit shall be Director’s Salaries and expenses, Corporation Income Tax, and depreciation on buildings. 4. ...