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The respondent insisted that the cost was only $16,447.02 and thatthe $138,552.65 differential must be considered as a benefit received from the company under the terms of section 15 of the Income Tax Act, R.S.C. 1952, c. 148 (am. ... He said he had no intention to sell it and had not considered leasing it. ... Is this the amount considered as a transfer to Mr. Pellerin, since he was the owner of the boring mill? ...

He wanted the appellant to be considered as the vendor that offered the best quality meat in the environs of Drummondville. ... The corporation's farming operations must be considered in relation to all other income earning activities of the corporation. ... Much of the criteria listed by Dickson, J. to be considered in determining “chief source of income" and whether a taxpayer is a Class I farmer is not applicable to this case. ...

Pursuant to the regulations under the Family Benefits Act the amount a qualifying individual may receive is determined on the basis of income level and the right to receive support payments is considered income for purposes of that calculation. ... Where a matter of support and maintenance is being considered in a divorce forum after the granting of a divorce, the Court is obliged to consider all the factors relating thereto within the applicable provisions of the Divorce Act. ... Bishop and the children were ordered by the 1975 decree nisi, in the manner of incorporating the provisions of the 1973 order, after the Court had considered the factors set out in the Divorce Act. ...

Inventory adjustments were considered but then discarded because of the absence of any reliable system then in place. ... The respondent's position was that, given each of the transactions and the sequence of events, it may reasonably be considered that one of their main purposes was to avoid Part II tax. ... The focus of subsection 181(5) is one of anti-avoidance; it applies where it could reasonably be considered that one of the main purposes of the one or more transactions was to avoid the Part Il corporate distribution tax. ...

This amendment is considered to have been added for purposes of clarification only and is not interpreted to mean that such was not the intention of the legislators in respect of earlier years. 9. ... There is no reason why any income earned by it should not be considered as prima facie income from a business so long as it is recognized that the presumption is a rebuttable one. ... However, the fact that a particular taxpayer is a corporation is a very relevant matter to be considered because of the existence of the presumption and its implications in terms of the evidentiary burden resting on the appellant. ...

On reading the T7W-C and the respondent's reply one may reasonably conclude that he considered only the subject propery was sold in 1974 and the fair market value of that property on December 31, 1971, Valuation Day, was $445,000. ... It appears the respondent never considered its value, or even its existence. ... Mr Walker revealed that at one point in time the appellant considered converting the property to residential use and selling the property as such. ...

Would you please confirm the above by signing this letter in order that my right to option could be considered at an end and the transaction can be terminated as described above. ... It is to be assumed that the landlord in this case assigned her business to the limited company for some good reason which she considered to be of an advantage to her. ... He felt the operation of Royal Tower should be considered his operation, not that of the company. ...

The following criteria should be considered: the profit and loss experience in past years, the taxpayer’s training, the taxpayer’s intended course of action, the capability of the venture as capitalized to show a profit after charging capital cost allowance. ... When what preceded 1977 and what followed 1978 is carefully considered, I believe one is driven to the conclusion that in these two years the appellants were not in the first class. ... These appeals have been considered from the perspective of whether, even though the conclusion is that the appellants were not in the first class in 1977, could they be regarded as being there in 1978? ...

Counsel for the appellant suggested that accounting was a pertinent and an important factor to be considered in the determination of the issue. ... Counsel for the appellant concluded that the amounts in issue could not, by any standard, be considered as taxable income to the appellant in any year. ... In assessing the appellant in 1980, the Minister could have and should have considered and given effect to the ceiling payment clauses of the University contract in his computation of the appellant’s 1977 and 1978 true taxable income. ...

[Emphasis added.] [40] If it includes no personal element and is clearly commercial, the taxpayer's activity is considered a source of business or property income. ... Uh, I went a bit farther, I even went into the plants, we promised to exchange samples... [22]- When asked about the cities that were considered potential clients, Mr. Tremblay said: [translation] Yes, I met with people, we talked, we exchanged calls, we wanted to see each other, we exchanged... documents that I had, interests.... [23]- When asked about the companies that were considered potential clients, Mr. ...