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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. ...

No competing source existed.Counsel referred to dictionary definitions of the word "source" and to decisions in which the meaning of the term “source of income" was considered. ...

Morden, J. implied that the fact that the solicitor in that case was not called may be considered in weighing the evidence. ...

He considered these all to be business purposes-related. He sets out in argument, and gave evidence in support of, the periods of time that he occupied the property personally. ...

We tried a sandbox... we were trying all sorts of different things to get new designs, so it was never even considered that we would need to have blueprints for the things that we were working on... ...

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. ...

Both the interest-free amounts and certain items of travel were not considered proper by Revenue Canada, and such are set out above. ...

They also submit that servicemen resident In Quebec before going overseas were taxed under paragraph 250(1)(b) of the Act, that is, as persons deemed resident in Canada, and that the province of Quebec considered them not to be resident in the province and therefore exempt from provincial income tax. ...

Counsel for the Minister however contends that the $169,500 should be considered as a shareholder benefit or appropriation as opposed to earned income. ...

However, nothing in the documents signed this day shall be considered as causing any of the parties hereto to lose any right whatever against any other party in the said case; 3. ...