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Robinette submitted that as the mortgages were bought to keep and not to sell, the transactions could not be considered as trading or as an adventure in the nature of trade. ... The mortgages in question bore what he considered a fair return on his investments. ... Peter Dixon & Son, Ltd., 25 T.C. 358, the Court of Appeal considered the nature of discounts and premiums received by the taxpayer from a subsidiary company which it had established in Finland. ...

,The hogs were sold and the proceeds of their sale in excess of their cost were considered as a reduction in the cost of butter manufacture. ... He considered this to be a first payment on his poultry. On March 1, 1949, he received another statement showing the grade of the poultry delivered by him, the number of pounds, the price, and the value, which came to $38.55. ... McPhail meant his own produce and that of his neighbours who were members of the association and, while he had no contract whereby the property in his produce continued to be his and expected only money in return for it, he considered that the net proceeds of its sale was his. ...

Question 2: Were international tax measures considered as part of the Technical Committee’s mandate? ... Question 3: Were the FAPI rules considered as part of the Technical Committee’s mandate? ... Question 4: Were the transfer pricing rules considered as part of the Technical Committee’s mandate? ...

These articles thus also are not admissible. [22] Although the 2009 letter to the CRA and the post-Decisions correspondence might be considered background information in their most favourable light, in my view they do not add anything new. ... The Decisions were not unreasonable [39] I find that the Applicants essentially request the Court to reweigh and reassess the evidence considered by the third reviewer. ... : Vavilov, above at para 97, citing Komolafe v Canada (Minister of Citizenship and Immigration), 2013 FC 431 at para 11. [42] Having considered the Decisions and underlying Third-level Taxpayer Relief Fact Sheets [Fact Sheets] carefully, I conclude that they do not disclose a reviewable error warranting the Court’s intervention. ...

That said, the receipts and their contents will not be considered by the Court in analyzing the substantive issues that the Officer was mandated to decide. ... However, the Officer does not explain why the receipts, which she did not review, do not correspond to the wide range of documents considered “acceptable” under the guidelines. ... The Officer’s report does not demonstrate that the CRA carefully reviewed and considered Mr. ...

Lavigne’s amended return and considered it in her notes of February 7 and February 14, 2023. [32] The Officer’s notes further state that Ms. ... This is what establishes the taxpayer’s actual situation, and what must be considered for purposes of eligibility for the CRB. [36] The capital cost allowance initially taken by Ms. ... Lavigne had failed to demonstrate that she met the $5,000 eligibility criterion. [38] On reading the Decision and the third review Officer’s notes, I note that the CRA considered Ms. ...

Robinette submitted that as the mortgages were bought to keep and not to sell, the transactions could not be considered as trading or as an adventure in the nature of trade. ... The mortgages in question bore what he considered a fair return on his investments. ... Peter Dixon & Son, Ltd., 25 T.C. 353, the Court of Appeal considered the nature of discounts and premiums received by the taxpayer from a subsidiary company which it had established in Finland. ...

The Submissions of the Parties [22] As noted above, the general tenor of the Respondent’s cost submissions is that LFMI, HWLH and Husky had a common goal and were working in concert and that when all three appeals are considered together the Respondent was successful. ... In such a case, it is for the Tax Court judge to determine the impact of this factor on the award of costs. [39] The Respondent accepts that LFMI was successful but submits that this success must be considered in the context of the overall success of the Respondent. ... While the concept of “beneficial owner” had been considered by the Tax Court and Federal Court of Appeal in the prior decisions of Prévost Car Inc. v. ...

Obviously Maple Leaf considered these amounts as its liability to those three persons. ... Therefore he stated: So for this reason "l have not considered this exhibit, and I put it aside. ... He signed it because he considered that the unpaid commission was not rightly his and should revert to Maple Leaf. ...

However, with respect to siblings, unless the facts indicate otherwise, generally one sibling would not be considered to have influence over another. In addition to the general factors described above, the composition of the board of directors and the control of day-to-day management and operation of the business would be considered.                                                                              ... No written management agreement had been considered necessary when ML1 was replaced by ML2. ...