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., supra, the Federal Court of Appeal laid out certain matters which should be considered by this Court when hearing these appeals. ... Nevertheless, they considered it to be his business in fact, albeit not in law ... There were some factors that he considered just superficially and others about which he was mistaken. ...

He agreed that sale number four, which he considered was not "back land" and it had 146 feet of frontage. [16]     Parcel D would have a value of $3,881 based on the price per acre. ... At page 5 he considered that the highest and best use of the subject property would have been land banking for future unspecified development purposes. ... As earlier indicated on page 23 the appraiser considered this to be a building lot when it was not big enough for a building lot. ...

No. 1020, Judge Mogan, T.C.C., considered the status of workers supplying services to a non-profit organization funded mainly by the federal government. ... Canada, 2002 DTC 6853, the Federal Court of Appeal- post- Sagaz- considered the income tax appeal of a mechanical engineer specializing within the aerospace industry. ... Considering, however, the fact that the integration factor is to be considered from the perspective of the employee, it is clear that this integration was an incomplete one. ...

Some came back as hazardous and some were not considered to be hazardous. ... It was not considered to be hazardous then. [20] She was referred to the articles of incorporation of SPCMA, to the activities set out therein and its by-laws. She said that these were their objects and that there were no renegade activities considered that were not in the by-laws. ...

This was a Statement of Real Estate Rentals for the Appellant for the year 1996. [43]          In cross-examination the witness was asked what were the possible revenues that she considered in the care giving expense venture and she said that the agreement provided for $300 a month per child or $10 per day. [44]          With respect to the alleged rental losses, she was asked what sources of income were considered for Apartment No. 1 and she said that there was no rental income considered because it was used for looking after the children. ... If this were to be considered to be an adventure in the nature of trade, the real estate would have to become part of the inventory. ... The more closely a taxpayer's business or occupation is related to real estate transactions, the more likely it is that the income will be considered business income rather than capital gain. ...

Where serviced lots are acquired, site development is considered to begin at the earliest date the taxpayer starts to install further services to the lots or the day it starts to pour footings. ... The Court considered that the payment to be, in effect, a prepayment of city taxes. ... Therefore, the carrying charges and property taxes must be added to the cost of inventory under subsection 10(1.1). [112] With respect to all of these items which can be considered to be “soft costs”, the Court is satisfied that these were incurred during the “construction period”. ...

Although evidence of a contracting party’s subjective intention is not to be considered, exchanges can be considered as part of the factual background and circumstances. ... Since the Court considered and rejected that argument, the Fuel ITCs remained a common issue in both appeals and was fully resolved by the Decision. [28]         Admittedly, BCF presented that argument. ... In Sable Offshore Energy Inc. v Ameron International Corp., 2013 SCC 37, [2013] 2 S.C.R. 623 [Sable Offshore], the Supreme Court of Canada considered the purpose of settlement privilege. ...

Workers such as Melissa were not considered as employees by the appellant ... Other factors, such as the lack of job security, the absence of employee benefits, freedom of choice, and mobility may also be considered (Wolf, supra, at paragraph 120; Lang v. ... The respondent conceded that the level of control should be considered as a neutral factor as Melissa was working according to her own schedule, did not contact Ms.  ...

The Applicant points out that the Adjudicator only considered whether the penalty was in compliance with the Customs Enforcement Manual (Guidelines). ... Nonetheless, the Respondents submit that the Minister considered all circumstances of the matter and the record before him in arriving at the Decision ... Fabiano is quite clear in his affidavit that, in making his Decision on behalf of the Minister, he considered the comments of the Seizing Officer. ...

Therefore, the place of residence of the employee should not be considered a connecting factor where the question is the location of employment income. ... Shilling argues that the fact that the income is earned as a result of performing services for native people should be considered a connecting factor. ... In my view, if the benefit to a reserve is to be taken into account, the advantage to NLS must be considered to be a factor that connects Ms. ...