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It is not for the reviewing court to weigh and reassess the evidence considered by the decision maker (Vavilov at para 125). [40] A reasonable decision is one that is made on the basis of a coherent and rational chain of analysis, and that is justified in light of the facts and law that constrain the decision maker. ... In rendering her decision, the officer considered the applicant’s arguments. ... The applicant did not indicate what other submissions he was allegedly prevented from making. [68] The Notes and the review report mention that the officer considered the applicant’s statements with the information noted in her review report. ...

., 648, in. which the above doctrine’ was Fully considered and adopted. ... I. do not think that it has: more than that I cannot conceive how it could be considered capital under the law in force in 1929. ... Clause 139 of the articles was also considered. This case, decided mostly on the interpretation of the memorandum of agreement and articles of association of the Company and on questions of fact is, it seems to me, of very little assistance, if any, in deciding the issues herein. ...

"(ii) The balance of the residue of my estate shall be divided into as many equal shares as there may be children of mine living at the time of my decease, and children of mine who have predeceased me leaving issue or widow as the case may be, and such share shall be dealt with in the following manner:— Share of a minor child: So much of the income as shall in their absolute discretion be considered advisable, my trustees and executors shall pay to the guardian of such infant for his or her maintenance, support and education until he or she arrives at the full age of twenty-one years; the balance of the income to be added to the principal of such share; <(Shares of daughters: The income on the share of each daughter of the full age of twenty-one years or when such daughter arrives at the full age of twenty-one years, shall be paid to her for and during the term of her natural life, and after her death, such share to be divided among her issue in such proportions as she may by 'will appoint, and subject to such terms as she may direct by will, and in default of such appointment to be divided equally among her issue, and the issue of any child or children of such daughter who may have died, per stirpes, the issue of any deceased child or children to take the share which would have gone to the parent if living. ‘* Shares of sons: The income on the share of each son of the full age of twenty-one years, or after he arrives at the full age of twenty-one years, shall be paid to such son until he arrives at the age of twenty-five years, when one-half of the capital shall be transferred to him, and the income of the other half of the capital shall be paid to him until he arrives at the age of thirty years when the balance of the capital shall be paid to the said son. ‘‘In case, however, one or more of my sons should die before he is entitled to receive the whole capital of his share, the said share, or any part thereof which such son has not received or have become entitled to receive, shall go to his widow or children in such proportions as he shall by will appoint, but any appointment to his widow shall only be of the income until her death or remarraige, whichever first occurs, and in case such son should die intestate, then his widow shall be entitled to the income of such share or such part of such share until her death or remarriage, whichever first occurs, and the capital of such share shall be divided among the children of such deceased son and the issue of any deceased issue per stirpes, the children taking the share that the parent would have taken if living; and in case any son should die without issue, then, subject to the provision aforesaid for his widow, such share shall be added to the other shares in equal proportions, the share set aside in respect of any who predeceases me shall be disposed of in the same manner both as to income and principal. ‘ ’ From the date of its organization Port Credit Realty Ltd. was considered for income tax purposes as a personal corporation; it was so considered not only during the lifetime of James Harris but also after his decease which occurred on January 1, 1929, for the taxation periods of 1929, 1930, 1931, 1932, 1933 and 1934. ... Port Credit Realty Ltd. has, since the decease of James Harris, preserved all the characteristics of a personal corporation and I see no reason why it ought not to be considered as such. ...

Snyder declared that it was indifferent to him as well as to his company whether this sum of $25,000 was considered as a fee in accordance with the explanations furnished by the witness or whether it was looked upon as a payment on account of the A.O.A. shares. ... It seems to me obvious that Trudeau considered this sum as forming part of the purchase price of his interests in the A.O.A. ... Snyder nevertheless considered it was important to have his co-operation as he had organized a company, namely, Automobile Owners’ Association, Limited, of which there was no other similar to it. ...

During the course of the trial, the President intimated that he considered this decision inapplicable. and it would appear from his reasons for judgment that he adhered to that view. ... In the present case, the Minister has considered and determined the two matters mentioned in section 98 of the Special War Revenue Act. ... Even with these assumptions, we cannot be aware of all the reasons that moved the Minister and, in any event, his jurisdiction under section 98 was dependent only upon his judgment that the goods were sold at a price which was less,—not, be it noted, less than what would be a fair price commercially or in view of competition or the lack of it,—but less than what he considered was the fair price on which the taxes should be imposed. ...

Crocket J. considered the test laid down in the Addie case (supra) and approved in the Tata case (supra) binding and held that the expenditure did not fall within the test. ... The legal expenses may, therefore, be considered as capital outlays or payments on account of capital. ... The next expenditures to be considered related to the House mining claims. ...

While the appeal to the learned trial Judge concerned the tax imposed upon the appellant in regard to all three of his activities and the appeal was dismissed, the reasons for judgment make it clear that in coming to the conclusion that the appellant was carrying on a business he had considered only the activities of the appellant in connection with the investment of his moneys. ... From this I infer that the learned trial Judge considered that the failure of the appellant to produce further evidence as to the manner in which he had carried on these activities in two or three of the years preceding and following 1940 justified the inference that he was selling securities at a profit and replacing them by others at lower prices, in the hope of disposing of them later at a profit, and that accordingly he was not merely investing his moneys in the manner indicated in the passage first above quoted. ... Under these circumstances, it can scarcely be suggested that the appellant intentionally held back any facts from the Court: if particulars of the investments made in these other years had been considered of importance the information could readily have been obtained on the cross-examination of the appellant. ...

LEFT HIS JOB: Since the TP was self-employed when he decided not to work, he is considered to have left his job voluntarily. ... Bekkai made much of his statement that the [translation] “applications were not stable”, claiming that the administrative decision maker had not considered it. ... In fact, it is presumed that an administrative decision maker has considered the evidence, unless it can be inferred otherwise. ...

Significance of a Determination as to Whether the Siblings Previously Occupied the Property as a Residence Prior to the Start of the Assessed Reporting Periods [26] The main factual dispute between the parties in connection with these appeals is whether the siblings resided at the Property at some point in time before the start of the assessed reporting periods. [27] Residential occupancy at the Property by the siblings is relevant to each of the three exemptions. [28] It is indirectly relevant to the Section 2 Exemption because an individual will be considered a builder under the definition in subsection 123(1) of the ETA if the subject property was acquired in the course of a business or an adventure or concern in the nature of trade. ... There is nothing in the language to suggest that the nature of residential occupancy at the property has to be as the individual’s principal place of residence. [38] Therefore, if the siblings are found to be builders in relation to the Property, a self-supply of the Property after the completion of construction or substantial renovation would arise if the siblings are considered to have occupied the Property as a residence (subject to the exemption under subsection 191(5) of the ETA), notwithstanding that the siblings could also be considered to be resident elsewhere for part of the relevant timeframe. [39] The Appellants assert that they occupied the Property as their residence late in 2012 or the start of 2013. [40] The only direct evidence tendered by the Appellants in support of their position was their respective testimonies. ... But I accepted the siblings’ testimony that those were not services that they considered essential in their circumstances. [45] In the result, I have concluded on a balance of probabilities that the Appellants occupied the Property as a residence at, or shortly after, the end of the 2012 calendar year. ...

The First Reviewer also noted that investment losses are not considered a withdrawal. [8] In January 2023, the Applicant requested a second review for reconsideration and removal of the tax charges [Second Request]. ... The Second Reviewer summarized the Applicant’s submissions in her Second Request and noted that investment losses are not considered a withdrawal and not part of the TFSA contribution room. ... The Second Reviewer is presumed to have considered all evidence before her but was not required to respond to every argument, particularly if it were not central to the Second Request (Vavilov at para 128). ...