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He also made submissions on H&C grounds similar to those the IAD had previously considered. ... On November 20, 2018, the Applicant made further submissions, asking that his May 2018 submissions be considered. ... However, there is a rebuttable presumption that the decision-maker has considered all the evidence. ...

The Decision notes the Officer considered the evidence provided with the Applicant’s application, which would include these results. ... In my view, this characterization represents an explanation for the Officer’s overall conclusions that the Applicant was unable to take part in short, routine conversations about everyday topics and was unable to use vocabulary that is adequate for routine oral communication. [22]   Finally, I have considered the Applicant’s submissions surrounding the Officer’s scoring of the eight individual questions, which the CTR indicates were posed at the February 2019 interview. ... The Officer took into account that the Applicant’s oral performance improved in the final two questions, but she nevertheless concluded the overall performance was insufficient to meet the language requirement. [24]   Having considered the Applicant’s arguments related to the reasonableness of the Decision, I find no basis for the Court to intervene. ...

Therefore, the location of the employee's principal residence was not considered in determining the allowance.   We submit that an allowance cannot be in respect of transportation between the appellant's principal place of residence and a special work site if the principal place of residence is not even considered in determining the allowance. ... Respondent counsel noted that this argument has not been previously considered by this Court. [24]   Counsel referred to decisions of this Court where the allowance was determined using the principal place of residence. ...

From May 1, 2005 to December 1, 2008, the appellant considered its anesthetic solutions containing epinephrine to be zero-rated supplies for GST purposes and thus did not charge GST to its clients in respect of them. In the latter part of 2008, it learned of a letter of interpretation issued by the Minister, which indicated that the Minister considered these sorts of solutions to be taxable supplies. ... C-11, section VI-154.4, confirms that paragraph 2(e) drugs are non-prescription, zero-rated drugs because: …they are needed for life-threatening conditions where there is no time to obtain a prescription. […] Thus, they are not zero-rated under paragraph 2(b) because they are not on the Prescription Drug List; yet it was considered appropriate to zero-rate them. ...

Relevance also could be established where the refused documents had been prepared in the context of the audit of the current taxpayer or had been considered by officials involved in the audit (para. 8, Superior). [11]   In Superior Plus Corp. v. ... Her Majesty 2019 TCC 112 (general procedure), per my colleague Visser J., wherein a motion to compel was considered in the context of a GAAR issue similar to that in this present motion. ... It is well established that a degree of judicial deference, again however slight, can be accorded statements of the Minister as to interpretation of fiscal legislation that are published in tax interpretation bulletins and information circulars. [16]   So, seeking to show from other CRA or related documentation (whether or not a copy happens to have been lodged in CRA's audit or objection files of the particular taxpayer, or otherwise considered by CRA in respect of the particular taxpayer) that the Minister's pleaded policy for subsection 245(4) purposes does not wholly conform with other administrative fiscal statements on the same subject should be acceptable, at least at the discovery stage. ...

Although her conclusion was not expressed in such terms, it is implicit from her Decision that she considered that this pre-condition had not been met. ... Moore came to anything that might remotely be considered to be apposite in this regard was when she referred to “financial burdens” and “the great expense to taxpayers.” ... Crampton” Chief Justice     FEDERAL COURT SOLICITORS OF RECORD DOCKET: T-676-19   STYLE OF CAUSE: ALEXANDRA MOORE v HER MAJESTY THE QUEEN MOTION IN WRITING CONSIDERED AT OTTAWA, ONTARIO PURSUANT TO RULE 369 OF THE FEDERAL COURTS RULES order and reasons: CRAMPTON C.J.   ...

I do agree that the transaction to be considered is that between Enns and John Deere, which produces the one per cent holdback, not the transaction between Enns and the customer which produces the original amounts. ... This judgment is based on the Court's acceptance of the assertion of counsel for the respondent at the hearing, that the transaction to be considered by the Court is that of the agreement between Enns and John Deere, not Enns and a customer. ... In the same way, it has not been shown that even if the above method of dealing with these amounts could be considered as setting up some kind of a reserve (a position not taken by the appellant, but raised by the respondent) that such a reserve has a viable basis in the Act. ...

That evidence is necessary in order to prove whether the losses she suffered during the years in question are deductible or, on the contrary, must be considered to have been personal or living expenses. ... The dedication the taxpayer has to making the farm profitable must also be considered. ... All things considered, these activities generated neither profits nor even gross income during the three years in question. ...

The matter was considered without personal appearance and a decision was rendered on December 15, 2020. ... In the circumstances, the allegations and pleas in defence should, in my view, have been left for the trial judge to determine based on the evidence and submissions that the parties put forward. [28] The Defendant objects to the paragraphs being struck without leave to amend on the grounds that the Plaintiff had not sought that relief nor had there been any notice provided that it was being considered by the Court. [29] Rule 221 (1) provides that a pleading or anything contained therein may, by order, be struck out with or without leave to amend. ... Mosley" Judge FEDERAL COURT SOLICITORS OF RECORD DOCKET: T-1443-18 STYLE OF CAUSE: AUGUST IMAGE, LLC v AIRG INC MOTION IN WRITING CONSIDERED AT OTTAWA, ONTARIO PURSUANT TO RULE 369 OF THE FEDERAL COURTS RULES ORDER AND REASONS: MOSLEY J. ...

Therefore, I have not considered that information in my review of the Decision. ... The officer considered the medical information and the fact that the note from Mr. ... Cheeseman’s first two Requests were considered in depth by the CRA as reflected in the taxpayer relief fact sheets completed by CRA officers. ...