Search - consideration

Filter by Type:

Results 3961 - 3970 of 11351 for consideration
TCC

Gilbert Brodeur v. Minister of National Revenue, [1985] 2 CTC 2201, 85 DTC 514

In such a case the alimony or allowance cannot be a total fixed amount payable by instalments up to the amount of $20,000 over a period of five years as in the case at bar, as the consideration for alimony or an allowance is the need of the creditor, whereas here the consideration is the waiver of benefits resulting from the marriage contract. 5.03.6 The Court must dismiss the appeal concerning the monthly payments of $300. ...
TCC

Dennis B Kanten v. Minister of National Revenue, [1985] 2 CTC 2251, 85 DTC 575

Grantees are not required to provide any consideration for shares awarded under the Career Plan other than their service to the Company. ... I can see no material difference between that statement and the one made by counsel for the appellant (supra): “In consideration of these rights, which Texasgulf had agreed to compromise in its agreement with Aquitaine, he received a cash payment.” ...
TCC

Bernard a Hodson v. Minister of National Revenue, [1985] 2 CTC 2326, 85 DTC 615

The Court must no doubt ascertain the subject matter to which the particular tax is by the statute intended to be applied, but when once that is ascertained, it is not open to the Court to narrow or whittle down the operation of the Act by seeming considerations of hardship or of business convenience or the like. ... It is not the function of Courts of law to entertain questions of policy, and I am unable to give any weight to arguments based on the consideration whether a particular interpretation is more favourable to the Crown or to the subject. ...
TCC

Banksia Investments Limited v. Minister of National Revenue, [1984] CTC 2139, 84 DTC 1060

The consideration of the $288,280 was paid as follows: cash of about $75,000, assumption of first mortgage of $45,000 and mortgage back of $167,000. The consideration with respect to the second purchase was satisfied as follows: $195,000, assumption of first mortgage of about $70,000, and with a mortgage back for the balance. ...
TCC

Miriam Rumack v. Minister of National Revenue, [1984] CTC 2382, 84 DTC 1339

It is said that the ambiguity which would make the decisions of the Supreme Court of Canada just cited, applicable to this case arises out of giving consideration to paragraph 56(1)(d) in relation to subsection 56(2). ... Moreover, even if IT-365R could properly be taken into consideration, I do not regard it as furnishing reasons entitling the appellant to succeed. ...
TCC

John E Plewes, John D L Plewes v. Minister of National Revenue, [1984] CTC 2585, 84 DTC 1582

By Indenture dated March 9, 1976, John Edward Plewes and Jessie Lenah Plewes, his wife, agreed to sell the business known as Nottawa Fruit Market for a total consideration of $158,000.00 to Gerald Winston Wylie and Ruth Anne Wylie. ... Where a taxpayer in the business of farming retains the title to his farm and merely sells the right to harvest the crop therefrom, the consideration so paid for that right is income to the vendor and an allowable deduction to the purchaser for tax purposes. 4.03.6 In the instant case, the agreement provides a fixed price for asparagus plants. ...
TCC

Moreno Boudreau v. Minister of National Revenue, [1984] CTC 2863, 84 DTC 1789

Upon consideration of the evidence, and having regard to the prime location of the subject property, I am of the opinion that the fair market value of the subject land at Valuation Day would be $25,500. ... Upon consideration of the evidence, and noting that the structure was of a mixed type of construction of barn/warehouse or warehouse/barn, I am of the opinion that Mr Stilwell’s value would be too conservative and that a fair figure to be attributed to the fair market value of the building as at Valuation Day would be $15,000. ...
FCTD

Frederick G Vivian and Rex T Parsons v. Her Majesty the Queen, [1983] CTC 107, [1983] DTC 5144

One of the reasons, aside from income tax considerations, for the reorganization was to permit Vivian and Parsons, individually, to pursue their particular professional interests and establish personal identities in the practice of their profession independent of Design and their association with each other. ... I find that the interposition of the management companies (1) had no bona fide business purpose, (2) had, primarily, the purpose of directly reducing their income tax liabilities, (3) had, secondarily, an estate planning purpose which, in the absence of credible evidence to the contrary, must be taken to have also been solely motivated by tax and personal, not business, considerations and (4) was not a sham in the generally accepted legal sense of that word. ...
T Rev B decision

Vincent Debenedictis, Giovanna Debenedictis v. Minister of National Revenue, [1983] CTC 2183, 83 DTC 167

The consideration paid was a demand promissory note. The City of Hamilton expropriated about seventeen acres of land in 1975. ... Accordingly, if there be circumstances which are supportive of the purchaser’s declaration of intention or contradictory to or inconsistent with it, they, too, must be taken into consideration. ...
T Rev B decision

Harold Henschell v. Minister of National Revenue, [1983] CTC 2296, 83 DTC 263

I should have thought that a truly objective analysis would require that consideration be given initially to all sales, whether high or low, and that there would follow a sorting out process designed to reject from final consideration only those which, for some reason other than price paid, are found to be poor indicators of the market value of the subject. ...

Pages