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By virtue of this definition, a single operation is to be considered as a business although it is an isolated venture entirely unconnected with the taxpayer's profession or occupation. ...

He examined four transactions that he considered comparable. He said that Mr. ...

In the original Moldowan decision, these factors were enumerated as follows: 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 capital cost allowance. ...

(i) the said amounts referred to in paragraph (h) relate to a capital outlay and accordingly are considered to be additions to the capital cost of the assets; She said in her response that the previous paragraph response applied to this one. ...

The Minister of National Revenue, APP-1992(IT), at page 3, Judge Sarchuk of this Court cited a passage from Sopinka and Lederman, The Law of Evidence in Civil Cases, in which the authors comment that the failure to call a witness may be considered as a circumstance unfavourable to an appellant's position. ...

The Queen, [1987] 1 S.C.R. 32, the Supreme Court restated the rule that in a tax matter what must be considered is what was done, not what might have been done. ...

Logic and common sense is on my side: it is inconceivable that a business of this size, located in this neighbourhood (considered one of Montréal's poorest) could generate income such as you indicate for March, June and August 1990 and February 1991, for example.... [8]            Only the appellant testified in support of his appeals. ...

The tax courts have considered a tribunal to be one that could issue a decree, make an order or deliver a judgment that would affect the marriage. ...

If in fact the hypothesis that there was a dual contract has the legal effects reckoned on by the respondent, it is not based on any evidence in this case and could most certainly not have been considered, and a fortiori adopted, by the judge. ...

ANALYSIS AND CONCLUSION: [15]          The question of whether an order of the Court of Queen's Bench of Alberta is binding upon an Appellant affected thereby must be considered in an appeal to this Court. ...