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Choulli had developed in the Appellants’ case, and which would be considered by the GAAR Committee. ... The assertion that other analyses were not considered by the Minister’s auditors concerning the Appellants is possible, but not necessarily more likely than not. ... Situated as preamble overtures in the replies, frankly, features rather than diminishes such salvos. [149] The Respondent shall provide a description of the “strategies” and “opportunities” considered and a description by list of those ignored and irrelevant. ...

Thus any course by which such a serious consequence may be avoided must be carefully considered by our courts. ...

The judge carefully and comprehensively considered and analysed the evidence before her. ...

To enable Poitras Frères to produce the logs and manufacture the lumber, the appellant made advances from time to time which were to be considered as payments on account of the purchase price of the products. ...

I appreciate that the organization's actions of facilitating development of youth within that setting could possibly be considered charitable. ...

In these circumstances the interest income must be considered to be income from property. [3]      The appellant argued that the test as to whether interest income is or is not from property should be based on whether the fund which generates the interest is set aside as a dedicated fund for the legitimate purposes of the club. ...

The judge considered that all such fees were incurred for the purpose of keeping the service station in operation. ...

Although he was not dealing in what is normally considered to be a subject of commerce such as commodities, the transaction from its very inception was purely speculative in character and was, in our opinion, as a matter of law, a venture in the nature of trade. ...

We respectfully agree with the Motions Judge that the “key factor” to be considered here is whether the appellant has an arguable case to present to a reviewing judge. ...

It knew or ought to have known that the information which it provided to the Department officials would be considered in dealing with the application to have its charitable status reinstated. ...