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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. ...

Smiroldo had a bad customer and driving record and he was told by Tiger that he would not be considered for an open downtown, higher-volume, zone until he improved. ...

One can only conclude that the Minister must have considered those to be reasonable start-up years. ...

Every expense must be justified, particularly if the facts suggest that the expenses may have been personal in nature. [47]          In such a case, it is important that the taxpayer who has been the subject of an assessment in which certain expenses have been considered to be personal be able to show on a preponderance of evidence that those expenses were necessary and required for the operation of the business or for the practice of the profession. [48]          In the instant case, the appellant submitted evidence that was incomplete, deficient and confused in many respects, to the point that the Court was scarcely any more able to render judgment after the appellant had presented the evidence than it had been before the trial started. [49]          In the circumstances, having regard to the evidence, it is very difficult, not to say impossible, to determine objectively which expenses are allowable and which are not since the evidence was incomplete, deficient and very insufficient, so much so that a clear distinction cannot be made. [50]          Consequently, I have no other choice but to make a determination regarding the expenses based on an exhibit which the appellant himself filed in evidence (Exhibit A-11). [51]          For the 1992 taxation year, the respondent allowed expenses totalling $4,543.03 and disallowed expenses of $25,490.70 for total expenses claimed of $30,033.75. ...

The discretion to adjourn is vested in the court, and although the position taken by counsel for the Minister was a factor to be considered in its exercise, the fact cannot be determinative. [10]          As this court has observed in Adams v. ...

I should have thought that if the Appellant was told that; and I believe the Appellant when she stated that she was given such assurance, some person from the Clinic should have been anxious to come to Court to support the Appellant and explain what their qualifications were and whether nutritional counselling could be considered part of a self-governing health profession. ...

Johnstone are considered to have been spouses, then payments pursuant to the written Agreement would be deductible. ...

The Federal Court of Appeal in Johnston considered the appeal of a taxpayer who had been born with a congenital condition which affected the taxpayer's ability to walk, and feed and dress himself. ...

Accordingly, with respect, I do not concur with the finding in the Davis case and I do not accept the submission of Appellants' counsel that consideration was given for the dividends received by them.... [20]          Finally, Judge Bonner of this Court also considered this matter in Ruffolo v. ...

He hired employees when he considered it necessary and set their wages.... ...