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Results 3921 - 3930 of 11351 for consideration
TCC

Newfoundland Tractor and Equipment Co. v. R., [1996] 2 CTC 2250, 96 DTC 1202

By the act of leasing the owner or lessor parts with the use or the right to use the property or equipment under consideration. ... The lessor gives the right to use the vessel to the lessee in consideration for the rent to be paid to the lessor by the lessee. ...
TCC

Furukawa v. R., [1996] 2 CTC 2641

As part of the purchase of the units, Lumberton agreed to issue to the Appellant “certain flow-through shares” of Lumberton and “renounce” in favour of the Appellant pursuant to paragraph 66(12.6) of the Income Tax Act (the “Act”), Canadian Exploration Expense (“CEE”) in the amount equal to the consideration of $7,500. ... Lifetime golf playing privileges, as well as the option to purchase a one-quarter acre building lot at the golf course were both future considerations, both of which never in fact materialized. ...
FCTD

Publi-Hebdos Inc. v. Her Majesty the Queen, [1995] 2 CTC 330, 95 DTC 5547

As such a person, for a consideration, it agreed to put an advertisement on behalf of the advertiser in its (the appellant’s) newspaper so that, when a member of the public got the newspaper, the advertiser’s message would, it might be hoped, be communicated to him. ... The contract for services is now defined as such in art. 2098 of the Civil Code. 9 During the relevant period art. 1600 of the Civil Code of Lower Canada defined the contract for the lease of things as follows: The lease of things is a contract by which the lessor brings himself towards the lessee to grant him the enjoyment of a thing during a certain time, for a consideration, the rent. 10 Tome 12, Montréal, Wilson & Lafleur Ltée, 1951, at page 300. ...
TCC

Robert M.P. Daudlin v. Her Majesty the Queen, [1995] 2 CTC 2731

In the consideration of the proposed contractual arrangements with Marineland, the appellant was influenced by the substantial revenue guarantees offered by Marineland in the early years of the program to cover the fixed costs of insurance, moorage and upkeep and the revenues projected over a ten-year period for any owner of a motor vessel participating in the yacht shelter program. ... The moving of the boat to Ontario was dictated by business considerations. ...
TCC

Terry Vango v. Her Majesty the Queen (Informal Procedure), [1995] 2 CTC 2757, 96 DTC 3240

One consideration may point so clearly that it dominates other and vaguer indications in the contrary direction. ... The same considerations apply here as in Day & Ross Ltd. v. The Queen, [1976] C.T.C. 707, 76 D.T.C. 6433 (F.C.T.D.) and TNT Canada Inc. v. ...
FCTD

Re Howard D. Milne, [1995] 1 CTC 122

In March 1994 Revenue Canada and Howard Milne entered into an interim payment arrangement and agreed, in consideration for various things to be done and payments to be made by Howard Milne, that Revenue Canada would not take any legal action for four months. ... The Court pointed out at page 125 (D.T.C. 5068): Another important consideration in determining the issue before this Court is that the taxpayer has the right to apply to a court to prevent a sale or disposition or assets seized and, pending final determination of the liability for tax, should a prima facie case be shown against the assessment and should it also be established that the taxpayer would be prejudiced by interim sale of the assets, he would be entitled to have any proposed sale or disposal of assets stayed or, in special circumstances to have the execution lifted against certain assets which might be likely to spoil or deteriorate. ...
FCTD

Re Robert Charles Hokanson, [1995] 1 CTC 314, 94 DTC 6683

Hokanson signed the notice agreeing, in consideration of Pacific Bailiff withdrawing their man in possession, that he would act as Pacific Bailiff’s bailee and further he agreed that the withdrawal of the man in possession did not constitute abandonment of the seizure. ... Such a direction must be based on relevant considerations and must not be made on an arbitrary basis" (page 805). ...
TCC

Anjalie Enterprises Limited, C/O Teichrob Unger & Co. v. Her Majesty the Queen, [1995] 1 CTC 2802

All the surrounding circumstances, therefore, have to be taken into consideration in dealing with a claim such as has been put forward on behalf of this appellant. ... I am of the opinion, therefore, that the explicit provisions of the legislation in respect of this particular item preclude taking into consideration facts which have not become known until many months afterwards and which could not have been foreseen by the taxpayer at the time of his determination. ...
TCC

Majean Investments Company Limited v. Her Majesty the Queen, [1994] 1 CTC 2578

Parrot, who, after deliberation, arrived at the purchase price and then presented it to the parties for their consideration. ... The Queen, [1983] C.T.C. 121, 83 D.T.C. 5148, at page 131 (D.T.C. 5157): While it has frequently been held that a Court should not, after considering all the expert and other evidence, merely adopt a figure somewhere between the figure sought by the contending parties, it has also been held that the Court may, when it does not find the evidence of any expert completely satisfying or conclusive, nor any comparable especially apt, form its own opinion of valuation, provided this is always based on the careful consideration of all the conflicting evidence. ...
TCC

WRD Borger Construction Ltd. v. The Queen, 2021 TCC 40 (Informal Procedure)

He added that the base of the pond was also uneven because there was a layer of riprap, which is a rock product used to protect the pond’s inlets and outlets from erosion. [7] Another physical consideration was hoop stress, which Mr. ... Kalaf was a very credible witness and the fact that he agreed in cross-examination that the appellant’s process was one of trial and error is not a consideration. [22] As an example of trial and error, the appellant purchased the 8-foot x 50-foot inflatable bladder dam whose manufacturer’s specifications indicated that it could control 6 feet of still water. [14] The culvert itself was 2.4 metres x 2.4 metres (i.e. 7.8 feet x 7.8 feet) with 4 metres (i.e. 13 feet) of head pressure exerted by the pond water. ...

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