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Rather, they were provided solely because of business considerations, namely sanitation, which gave rise to a rule precluding all employees from bringing their own food onto the casino premises. ...

The Agent authorizes this Company to endorse any cheques on behalf of the Agent as it deposits same and grants such authority absolutely and for valuable consideration." ...

To hold that those words in all circumstances mean that there must be a lapse of two years from the date an individual ceases to hold office as a director in accordance with the provisions of the relevant corporate legislation would in some instances, such as those under consideration, render the limitation period devoid of meaningful substance. ...

This question was not under consideration before the Federal Court of Appeal in Cival. ...

The Minister’s statutory delegate exercising the discretion had before him the relevant considerations on which to base a decision. ...

It was common ground that I should look at the circumstances surrounding the giving of the guarantee, notwithstanding the restrictive words of subparagraph 40(2)(g)(ii) of the Act which reads: (g) a taxpayer's loss, if any, from the disposition of a property, to the extent that it is (ii) a loss from the disposition of a debt or other right to receive an amount, unless the debt or right, as the case may be, was acquired by the taxpayer for the purpose of gaining or producing income from a business or property (other than exempt income) or as consideration for the disposition of capital property to a person with whom the taxpayer was dealing at arm's length. is nil. ...

He further stated that the object of the acquisition of Hartwil was to improve the profit potential of the appellant company and that no consideration whatsoever was given to building up Hartwil's financial position to pay dividends. ...

The particular document to which the learned judge attributed a great deal of weight, that is to say the agreement of July 1967 (Exhibit 4) in which a consideration of $100,000 is expressed as being for transfer of the interest of the appellant and Phillips and Lee in the timber harvesting licence which had not yet been granted but which was then expected to result from the joint application made in January 1967, is but one among a number of documents of some importance in resolving the present problem. ...

Fluctuations before December 31, 1971, whether resulting in gains or losses, are not to be taken into consideration. ...

  [5]                The Tax Court Judge found that the appellant’s ordinary business in the years under consideration did not include money lending. ...