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In my view the definition of “principal residence” contained in paragraph 54(g) is such that considerations as to what can lawfully and effectively be conveyed are irrelevant. ...

In this Court the taxpayer, often without legal counsel of his own, comes believing that in his actions he has acted properly and deserving of consideration. ...

The lower court judges erred by taking into consideration the amounts paid on account of tax subsequent to the commission of the offences. ...

His position was founded upon what he described as considerations of fairness and equity. ...

The appellant paid no rent or other consideration to North Canadian and the fair market rental value of the premises was at least $10,000 per annum during the years in question. ...

The minutes of that meeting record that: After due consideration, and upon motion duly made and seconded, it was resolved that an assignment in bankruptcy be made by the corporation. ...

In reassessing the Appellant as he did, the Respondent relied, inter alia, upon the following assumptions of fact: (a) that in September of 1974, the Appellant purchased 10,000 units of securities in Blue Vista Enterprises Limited (‘‘the Company”) for a total consideration of $50,000.00; (b) that in financing the purchase of securities from the Company the Appellant obtained loans in September of 1974 from the Toronto-Dominion Bank; (c) that the Appellant was one of the original incorporators of the Company, incorporated on June 5, 1974 under the laws of the Province of Ontario; (d) that the Company ceased carrying on operations less than one year after its incorporation; The only evidence adduced at the hearing was the testimony of the appellant. ...

An objective consideration of Walter Koritni’s testimony and the documentary evidence filed by the respondent, confirm that the appellants, albeit on a part-time basis in 1978 and 1979, were engaged in a farming operation and exclude any possibility that they were engaged in a hobby farm as “Gentlemen Farmers’’. ...

However, the issue in this case must be tested on broader considerations than a simple measurement of time spent. ...

The agreement between the appellant and Mr Towers called for payment to the appellant as consideration for his services of $5,000 on the closing in February, 1973 and a further $5,000 thirty days later. ...