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Indeed the auditor for Revenue Canada considered them such. Appellant's counsel argued that this conclusion foreclosed the Minister's argument that they were a return of consideration. ... The attachments associated with the Lumberton shares, while they are owed to the appellant, did not appear to influence the appellant's decision to purchase the shares and cannot reasonably be considered a return of the consideration of the sum of $7,500 paid for the shares. ... Since I have considered the issue as directed by the Federal Court of Appeal and since the appellant is successful, it is not necessary at this time to consider counsel's submission with respect to Continental Bank, supra. ...

Traditionally, expenses that simply make the taxpayer available to the business are not considered business expenses since the taxpayer is expected to be available to the business as a quid pro quo for business income received.... [6] I believe it would nevertheless be useful to cite lengthy excerpts from this decision to show that the distinction between a personal and a business expense is not always easy to determine and to establish the criteria that should be considered in ascertaining whether an expense is one of a personal or business nature. ... According to this test, if I interpret it correctly, any expense that must be made by a person in order to report for work will be considered a personal expense. ... Can haircuts be considered as supplies within the meaning of this subparagraph? ...

James Klimas was not considered to be the primary caregiver for the children; consequently, the Minister issued child tax benefit notices on May 12, 1998 for the base year 1994, and on June 19, 1998 for the base years 1995 and 1996, refusing the Appellant the eligibility for the CTB for the children. ... The presumption referred to in paragraph (f) of the definition of “eligible individual” in section 122.6 of the Act is thus not applicable and the factors set forth in section 6302 of the Regulations must be considered. [8] The appellant, Mr. ... No. 431. [31] In light of the factors to be considered, which are based on care, attention, participation and involvement, and in view of the evidence adduced in the present case, I must conclude that the appellant has brought insufficient evidence to demonstrate, on a balance of probabilities, that she has satisfied the condition set out in paragraph (b) of the definition of “eligible individual” in section 122.6 of the Act, namely that she was, during the periods in issue, the parent who primarily fulfilled the responsibility for the care and upbringing of the two children. [32] Therefore, the appeals are dismissed. ...

It is also the case that the parties’ mutual intention or stipulation as to the nature of their contractual relations should be considered and may prove to be a helpful tool in interpreting the nature of the contract for purposes of characterizing it under the Civil Code. ... Canada, 2009 FCA 47, 2009 DTC 5056, wherein the intention of the parties is described as an important factor to be considered in characterizing a contract for purposes of the Civil Code. ... That does not mean that taken as a whole, having considered all of the relevant considerations and indicia, there may not be an overall degree of direction and control and subordination sufficient to make it employment. ...

At that time he sought info into the number of years CRA would require for a disclosure to be considered complete. ... However, that disclosure could not be considered voluntary, as required by subparagraph 6(a) of the Information Circular because on September 2, 2004, the applicant received knowledge that he was being audited. ... As such, he claims that the conversation his representative had with the VDP officer in July 2004 was not considered as being the effective date for which voluntary disclosure took place and that this constitutes a breach of procedural fairness. [25]            Before the Court, the applicant suggests that Ms. ...

In his decision, Mario Côté concluded that the request could not be considered to be voluntary because it was made in response to a tax audit of a related person ... If the answer to either these questions is “NO”, the disclosure may be considered voluntary. 3.2.4.   ... For example, section 3.2.4 (Impact of Enforcement Activity) states: “If the answer to either of these questions is “NO”, the disclosure may be considered voluntary.” ...

  [27]            In the particular circumstances of this matter, I considered that the documents might assist the Court to understand the background to the application. As these were documents that should be in the possession of the respondent, I considered also that their admission would cause the respondent no prejudice. ... In her decision, the Director should have considered this, and taken into account when the executors could have first learned about this income and reported it for Corinne Kelley’s estate ...

[37]            The Assistant Commissioner properly considered all of the relevant evidence of the file. ... Stirling concluded that the applicant’s request for the period prior to June 14, 2001 had been considered, but ultimately rejected ... The Assistant Commissioner considered both of these factors in making his decision. ...

Abdulghafoor met the residency requirement and how he considered the evidence. [33]      Reasonableness, not perfection, is the standard. ... It is clear that the citizenship judge accepted the respondent’s travel history, and related days that she was physically present in Canada, as credible. [40]            The citizenship judge is presumed to have considered all of the evidence (Suleiman at para 23). ... There was no transcript of the hearing and the affidavit evidence relates to the evidence the citizenship judge considered. ...

The question, however, remains as to the proper party to be considered as the lessee. ... The Minister considered Tantramar as the lessee and the province the lessor, and as the Province was not a taxpayer, he gave the full allowance for depletion allotted to the mine to Tantramar. ... He did not act under them as he considered the appellant did not come within them. ...