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The benefit of the Contract was later assigned to the Appellant with the consent of Wood. t) In or about June of 1987, Wood anticipated that the Municipal District of Rocky View intended to down-zone the Land, and, by the aforesaid Contract, Wood employed the services of the Appellant in order to oppose the down-zoning of the Land, and, if successful, thereafter to take all such steps as may be necessary to obtain approval to subdivide the Land into 30 lots. u) The obligations of the Appellant were to: ii) to make representations to regulatory authorities as required in connection with design control relating to the Land; iii) to assist in co-ordinating road, water, gas, power, landscaping and act as casual supervisor of construction, and to assist in subdividing the Land into 30 lots; iv) to supply his services to assist the owner with an application to subdivide the Land into the Owner's Acreage and as many two acre parcels as may be permitted. v) In the event the Appellant was successful in opposing the down-zoning of the Land and the Land was subdivided, the consideration or fee payable to the Appellant was the grant to him of 2 two acres lots to be selected by him, at the time registration of such lots was possible. w) The Appellant was successful in opposing the down-zoning of the Land by September 13, 1988. Wood continued to engage the services of the Appellant with regard to the sub-division of the Land. y) The fully serviced lots 11 and 16 were transferred to the Appellant on January 11, 1990. z) As part of the work done in regard to getting approval for the development agreement, the Appellant did a feasibility study of the whole project which indicated the value of each lot. bb) The Appellant sold lot 11 on February 23, 1990 for the sum of $124,500.00, and the Affidavit of the Transferee on the Transfer of Land of the above transaction stated the fair market value of the land as $124,500.00. cc) The fair market value of lots 11 and 16 on November 7, 1989 was $124,500.00 and $90,000, respectively. dd) The return of income of the Appellant for his 1989 taxation year was signed by him on April 29, 1990, and the Appellant failed to report the aforesaid sum of $214,500.00 as the consideration paid to him by Wood in 1989, pursuant to the Contract. ... Regards Penalty v) In the return of income submitted by the Appellant in respect of its 1992 taxation year, it reported $35,000.00 as the value of the consideration paid to it by Allan Hodgson in regard to the services rendered by the Appellant to him pursuant to the provisions of the Contract. w) In its return of income for its 1990 taxation year the Appellant did not declare any income from the Contract, and thereby the Appellant by its servants and agents knowingly or under circumstances amounting to gross negligence made or participated, assented to and acquiesced in making the false statement that its income arising out of the aforesaid Contract during its 1990 taxation year was nil and thereby understated its income by $90,000.00. ...

The consideration for the above conveyance was $40,000 which was paid by the assumption of a registered mortgage to the Tuckett Estate for $25,000, and the balance of $15,000 was paid by William Morris. ... By deed dated May 1, 1945 (Exhibit F) William Morris conveyed the property to the appellant for the expressed consideration of natural love and affection and $2. ... I turn now to a consideration of the issues in this appeal and the manner in which they have come to this Court. ...

I was not asked to give special consideration to individual assets, either on the law or facts, the contention of the appellant being that all of the assets were in fact the property of the husband. ... And all the surrounding circumstances of the case should be taken into consideration to determine whether a gift or a resulting trust was intended.” ... In my view, after a careful consideration of the evidence, the appellant has wholly failed to rebut the presumption that in placing assets in the name of his wife, Mr. ...

Ltd. en considération des renseignements que l’intimé avait J* 7 h.: fournis à Canadian Chemical & Cellulose Co. ... In consideration for such action on your part, we hereby waive any and all claims which we might have against the said F. ... Ltd. en considération des renseignements que l’intimé avait fournis à Canadian Chemical & Cellulose Co. ...

Section 192 of the Companies Act provided that: "‘In the absence of other provisions in that behalf in the letters patent or by-laws of the company, (ce) all questions proposed for the consideration of the shareholders at such meetings shall be determined by the majority of votes, and the chairman presiding at such meetings shall have the casting vote in ease of an equality of the votes.’’ ... In my opinion this is the meaning of the word ‘interest’ in the enactment under consideration, and, where one company stands in such a relationship to another, the former can properly be said to have a controlling interest in the latter. ... Monmck Lid. (1949), 29 T.C. 379, where in the course of holding on particular facts that the respondent company was not one of the directors whereof had a controlling interest: therein, though two persons who for the purpose of the statute under consideration were to be regarded as directors held half the shares, Croom-Johnson, J. said at page 385; It is perfectly true that if this Company had a board of directors—and it has not—and if that board of directors had appointed a chairman, and if that chairman had happened to be Mr. ...

Mutual insurance means a contract of insurance, in which the consideration is not fixed or certain at the time the contract is made but is to be determined at the termination of the contract or at fixed periods during the term of the contract according to the experience of the insurer in respect of all similar contracts whether or not the maximum amount of such consideration is predetermined.’’ ... A premium note is defined by subsection (48) of Section 2 of the latter statute to mean:— ‘An instrument given as consideration for insurance whereby the maker undertakes to pay such sum or sums as are legally demanded by the insurer, the aggregate of such sums not to exceed an amount specified in the instrument and includes any undertaking to pay such sums regardless of the form thereof and whether or not accompanied by a deposit of money or security. ’ ’ The premium notes taken by the appellant company conform to the first part of this definition. ... Justice Hyndman, my consideration of the present matter leads me to a different conclusion. ...

Micsau would sell its AmalCo shares; c) A tuck-under reorganization is undertaken: Micsau would transfer its 3295 shares to Holdings in consideration for shares in Holdings on a taxable basis, allowing Micsau to use its high ACB in computing its resulting capital gain. ... In consideration, 4244 issued to Micsau Class D shares with an ACB and FMV of $31.5M. ... If the taxpayer can illustrate that there are other transactions that could have achieved the same result without triggering any tax, then, in my view, this would be a relevant consideration in determining whether or not the avoidance transaction is abusive. (…) [T]he alternative means by which the same result could have been realized is a relevant consideration in determining whether or not the avoidance transaction was abusive. ...

The form of the resolution, suggested in the above letter, it seems required further consideration and the appellant was so advised by the Minister of Railways, on October 3. ... I have, however, to point out that the wording of the voucher while correct as to amount, and because of that enabling me to accept the cheque, does not clearly state the arrangement made with me when the matter of compensation was under consideration by both of us. ... In reported cases of the very kind now under consideration I find that it is usual to have before the court evidence of all the circumstances attending such payments for the purpose of ascertaining their true character, in order to determine whether the same.was received as “income,” or otherwise. ...

Francoeur, in his quality of Minister of Public Works in His Majesty’s Government for the Province of Quebec, and. the suppliant company, the latter, in consideration of the sum of $813,747, undertook to erect the structural steel super-structure of the centre portion of a bridge over the St. ... Francoeur, in his quality of Minister of Public Works and Labour in his Majesty’s Government for the Province of Quebec, and the suppliant company, the latter, in consideration of the sum of $94,- 920, undertook to erect the superstructure of a bridge over the Gatineau River between the City of Hull and Gatineau Point and to furnish all materials and labour necessary for the execution of said contract; In virtue of said contract the said bridge was erected and, in respect of the materials therein incorporated, the suppliant was assessed in the sum of $2,766.68 for sales tax allegedly due; By a contract made on August 21, 1931, before E. ... (d), without taking into consideration the meaning and intent of the statute as a whole. ...

This consideration could not be given any weight against the plain meaning of the words of a statute, but in the case of those statutory provisions one ean, at best, only grope in the obscurity created by careless drafting. ... In my opinion the words of Harrison C.J. in the case above quoted are intended to indicate that the apportionment pre- scribed by the equalization by-law of 1876 was an unalterable basis for the levying of the tax in 1877, and his observation, in my view, has no relation to the method by which and the consideration on which the apportionment prescribed by the equalization by-law of 1876 was reached. ... I expressed my views in the following words: “.... by sec. 86 (now s. 90), the county council is given a broad discretion—so broad that it is entitled to take into its consideration the assessment rolls themselves; its own knowledge of values (see s. 88, now 92); the report of the valuators, if any appointed; and thereupon to form its Own opinion as to what is necessary to produce a just relation between the aggregate valuations of the different townships. ...