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Miller J. considered the phrase in 1146491 Ontario Ltd. v. R, 2002 G.T.C. 235. ... Beaubier J., at paragraph 9, considered the meaning of "consumption" and found it to mean "the action or fact of consuming or destroying" [3]. He then considered the meaning of "food" and found it to be "what is taken into the system to maintain life and growth, and to supply the waste of tissue; ailment, nourishment, provisions, victuals". ...

The first level Officer considered all of the factors outlined in section 33 of Information Circular 07-1R1 in arriving at her recommendations. ... She considered the Applicant’s first level review and the materials provided by the Applicant for the second level review. ... The second level Officer carefully considered the Applicant’s representations and reviewed the documents submitted in support of his request. ...

The Queen, 80 DTC 6194, [1980] CTC 198 (FCA) Heald, J:—We are all of the opinion that the learned trial judge correctly concluded that the appellant’s antiknock compound cannot be considered to be a “petroleum product’’ as that term is used in paragraph 83(A)(3)(a) of the Income Tax Act, RSC 1952, c 48. ... We also agree with his application of that definition to the facts of this case which resulted in his conclusion that because of the addition of the various substances foreign to petroleum and because of the extensive chemical processes to which the various elements are subjected in the process of producing the antiknock compound, that finished product, cannot, in ordinary parlance, be considered to be a “petroleum product’’ within the meaning of paragraph 83A(3)(a) referred to supra. ...

Finally, he considered the potential profitability of the farm and found that there was “no realistic expectation of a substantial profit”. Thus the learned trial judge considered all factors, and after weighing them together was entitled to reach the conclusion which he did. ...

Anderton exercising his stock option in 1997 and 1998 was within his control and was not considered an extenuating circumstance for the purposes of remission. ... Therefore, the Director General concluded that his health issues could not be considered extenuating circumstances for the purposes of remission. [19] Lastly, the Director General noted that it is generally not considered to be in the public interest to remit tax, penalties, or interest for taxation years for which taxpayers did not file an income tax return on time or pay any amounts owing as required, unless there were circumstances that rendered them incapable of doing so. [20] The Director General concluded that, having considered Mr. ... Anderton’s particular health problems. [22] The Decision concluded by stating that, having considered Mrs. ...

The respondent further asserts that the letters were not considered by the Minister and therefore cannot be considered by this Court ... It would appear preferably to include the letters in question in the appeal book and leave it to the panel hearing the appeal to determine the relevance of such documents and whether they should have been considered by the respondent. ...

The words “it may reasonably be considered” in subsection 15(1.1) clearly indicate that the evidence of necessary intent can be established if in the circumstances it is reasonable to consider that this was one of the purposes of the payment. ... It did not contain the words “may reasonably be considered that...”. This Court, for purposes of decision, assumed, without finding, that the test was subjective. ... He should instead have considered whether the evidence met the standard of objective reasonability which was required to overcome the onus on the taxpayer of proving that none of the purposes of the payment was a significant alteration of Dr. ...

Each case stands on its own merits. [4] In arriving at his decision, the Minister relied on the following allegations of facts contained in paragraph 4 of the Reply to the Notice of Appeal, which were admitted or denied: "(a) the Appellant was employed by the Employer as superintendent for an apartment building; (admitted) (b) the Appellant was provided with an apartment free of charge for the performance of his duties; (admitted) (c) at times, the Appellant received some extra duties pay of $8.00 per hour; (admitted) (d) the Appellant also received a bonus of $25.00 for each apartment, which he rented himself; (admitted) (e) effective for 1997 and later years, taxable benefits in kind are no longer insurable, except for the value of board and lodging enjoyed in a period if there are cash earnings paid in the period; (admitted) (f) the value of the rent ($500.00 per month) is considered insurable only in a period when cash earnings are received; (admitted) (g) the Appellant was paid on a bi-weekly basis; (admitted) (h) the last 27 pay periods from July 21, 1997 to July 31, 1998 had to be considered for the calculation of the insurable hours; (admitted) (i) the Appellant accumulated 98.50 hours of insurable employment during the last 27 pay periods; (denied) (j) the last 14 pay periods from January 29, 1998 to July 31, 1998 had to be considered for the calculation of the insurable earnings; (admitted) (k) the Appellant accumulated $1,528.00 of insurable earnings during the last 14 pay periods calculated as follows: earnings of $453.00, bonus of $75.00 and value of rent of $1,000.00. ... The value of the rent, at the monthly rate of $500, is considered insurable only in a period when cash earnings are received. ... The last 27 pay periods from July 21, 1997 to July 31, 1998 had to be considered for the calculation of the insurable hours. [7] The Respondent produced, as Exhibit R-1, an itemized statement, for the last 27 pay periods, the hours for extra duty, earnings, bonus and free rent. ...

., as he then was, reviewed many of the authorities which considered and discussed the provisions of this section. ... I am satisfied that in interpreting this section in the Savage case considered the Supreme Court of Canada considered the theme, the intent, and the policy object of the enactment. ... I do not regard the motivation behind the conferring of the benefits or the fact that the acceptance can be considered to have been a requirement of the appellant's employment to render paragraph 6(1)(a) inoperative in respect of them. ...

The amount of $650 is disallowed and must be considered as revenue. 6. ... As the burden of proof is on the appellant, this amount of $822 is disallowed and must be considered as revenue. 7. ... This amount is disallowed and must be considered as revenue. 7.2 Unidentified cheque April 24—$204-e- As the appellant does not remember what this amount represents, it must be disallowed and considered as revenue. 8. ...