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The final question was whether the realization by the receiver is a “liquidation, assignment or bankruptcy” within the meaning of the provisions under consideration. ... The provision under consideration created “a lien and charge… payable in priority over any other claim or right…”. ... The assessment entitled “Pre March 31, 1977” involves entirely different considerations. ...

Smith’s estate was not expenditure incurred by appellant ‘solely for the purpose of earning... profits or gains’ of its business; that the obligation to make the payments was undertaken by appellant in consideration of its acquisition of the right and opportunity to earn profits, i.e. of the right to conduct the business, and not for the purpose of producing profits in the conduct of the business.” ... It would be a strange result if the question, whether legal expenses incurred in enforcing or preserving a right should be regarded as an outlay on account of capital or on account of income, fell to be determined on a consideration not of the true nature of that right but of the nature of the ill-founded grounds on which it was disputed. ... It is, however, argued on behalf of the appellant that even if it be accepted that such legal expenses are not deductible when they have been incurred to dispute a claim of the tax authorities of the taxpayer’s own country, entirely different considerations apply when the outlay is made in order to determine the taxpayer’s position in relation to a claim by a foreign government. ...

Obviously, the public interest is a very important consideration in determining whether an interlocutory impounding order should be set aside. ... In his view the contention put forward by the appellants was not so immediately obvious as to exclude from consideration that put forward by the respondents. ... These considerations alone are sufficient to meet the public interest criterion. ...

Customs officers have consistently failed to apply Butler ’s command to consider the context and artistic merit of items under consideration.  ... No reader can find a dominant characteristic on a consideration of isolated passages and isolated words. ... They flow from the very nature of prior restraint, and require careful consideration by Parliament.  ...

In such cases, no consideration of subparagraph (i) is required in determining the taxation position of the taxpayer under subparagraph (ii). ... We therefore are required to go on to other considerations. I return to subparagraph (v) which is common to both paragraphs (9)(a) and (b) with the variation noted above. ...

Freeman J.A. held that upon fulfilling all of the obligations under the leases, it was not intended that Pegasus become the owner of the helicopters automatically or for nominal consideration.  ... The second type of agreement covered by the Act is a lease-option agreement, where the option is for nominal consideration; it is plain from the terms of the lease that the option will be exercised, and that the "lease" payments are in reality going to pay for the goods.  ...

The argument against that seems to have been directed mainly to the circumstance that the disposal was not voluntary but dictated by the Treasury and a considerable part of the reasoning was to meet that consideration. ... (The Chief Justice concurring):—The Income Tax Act, 1948 does not contain any further definition of "‘income’’ which requires consideration in this case than that to be found in Sections 3 and 4. ...

While the provisions of this will are not the same as those in question in the will under consideration in Singer v. ... When the maintenance of the appellant herself is taken into consideration, the total maintenance for the three approximates the amount of income here in question. ...

In the Supreme Court of Canada the prime consideration was not the breadth of the authorization but whether the Federal Court of Appeal had jurisdiction to entertain the application. ... In deciding whether to exercise the right last mentioned, he will be gov- [Page 508] erned by many considerations, dominant among which is the public interest and his duty as an executive officer of the government to administer the Act to the best of his ability. ...

The appellant may adduce facts constituting a prima facie case which remains unanswered; but in considering whether this has been done it is important not to forget, if it be so, that the facts are, in a special degree if not exclusively, within the appellant's cognizance; although this last is a consideration which, for obvious reasons, must not be pressed too far. ... Reverting to the contention already mentioned, that the transaction with which we are concerned being an isolated transaction it cannot be brought within the second alterna- [Page 56] tive of Lord Dunedin's test, this rule would have excluded from the scope of the tax the profits under consideration in the California Copper Syndicate's Case [19] and in Beynon v. ...