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I do not think that this consideration can weigh very heavily in the determination that must be made here. ...

and (C)       Does the differential treatment discriminate, by imposing a burden upon or withholding a benefit from the claimant in a manner which reflects the stereotypical application of presumed group or personal characteristics, or which otherwise has the effect of perpetuating or promoting the view that the individual is less capable or worthy of recognition or value as a human being or as a member of Canadian society, equally deserving of concern, respect, and consideration? ...

On the one hand, Linden J.A. wrote as follows in Friedberg, at page 2: Thus, a gift is a voluntary transfer of property owned by a donor to a donee, in return for which no benefit or consideration flows to the donor (see Heald J. in The Queen v. ...

These factors should then be analyzed to determine what weight they should be given in identifying the location of the property, in light of three consideration: (1) the purpose of the exemption under the Indian Act; (2) the type of property in question; and (3) the nature of the taxation of that property [Emphasis added]. ...

Counsel for the respondent asserted that the inference one may draw from this failure to act is that the fact that the debt was or was not paid was not a significant consideration in signing the consent to judgment or that the appellant was less concerned by the consent to judgment than by the possibility of benefiting from the Minister's error. ...

The respondent failed to discharge her burden respecting this part of the assessment. [77] However, different considerations apply to the other amounts subject to the penalty provided for in subsection 163(2) of the Act. ...

This appeared to be the paramount consideration of that Court. [40] In spite of the fact that this case was not appealed, this Court is not satisfied that it offers any consolation to the position taken by Counsel for the Appellant in the case at bar. [41] In the end result, the Court is satisfied that the assessment of the Minister was well founded. ...

Taking all of the factors set forth in Wiebe (supra), into consideration, I find the provision of mechanical services by Hansford to BTI- although carried out in the BTI shop- to have been done by him on his own account and not as an employee of BTI under a contract of service. ...

He said that he did not take into consideration whether or not a child was a horse owner or whether or not the client was referred to the Kings by a horse owner. ...

Farmer, (1910) 5 T.C. 529 at 536, Lord Dunedin said in part: Now, I don't say that this consideration is absolutely final or determinative, but in a rough way I think it is not a bad criterion of what is capital expenditure as against what is income expenditure to say that capital expenditure is a thing that is going to be spent once and for all, and income expenditure is a thing that is going to recur every year. ...