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QCSC decision

Robert Howard Smith, G Meredith Smith and Gardner Howard Smith, Executors of the Last Will and Testament of Edmund Howard Smith, Robert Howard Smith, Jr, Kathleen Patricia Smith, Gordon Edmund Howard Smith, Andrea Louise Smith (Wife of Lan David Ritchie), Philip Howard Smith and Dorothy Laura Smith (Wife of Henry Cole) v. Deputy Minister of Revenue of the Province of Quebec, [1973] CTC 136

In consideration of said sale, the newly formed company, Clarke Place Investments Inc, issued to the deceased 25,000 5% non-cumula- tive redeemable preferred shares of the par value of $100 each and 1,000 being all of the authorized common shares of the par value of $1 each, in its capital stock. ...
FCA

Minister of National Revenue, Appellant,, [1973] CTC 345, 73 DTC 5281

What is contemplated is a profit-making process consisting of such physical acts and the disposition of the products for a consideration by sale or other wise. ...
T Rev B decision

Maurice Alexander Clegg v. Minister of National Revenue, [1973] CTC 2014, 73 DTC 10

The problem here is this: Should the premium that an individual pays in exercising his option to obtain the extra coverage granted by the group-policy makers—in this case Mutual Life—be taken into consideration in calculating the benefit to him envisaged by the Act? ...
T Rev B decision

Charles a Specht v. Minister of National Revenue, [1973] CTC 2018, 73 DTC 25

In consideration of receiving $200,000 payable within a period of five years the appellant agreed to three undertakings by him as therein set forth. ...
T Rev B decision

Antoine Hullmann and Gabrielle Hullmann v. Minister of National Revenue, [1973] CTC 2106

From the evidence adduced in these appeals, I conclude that Antoine and Gabrielle Hullmann acquired the properties which are the subject matter under consideration for the purpose of resale and not for a long-term investment, that their conduct in these transactions was that of an adventure in the nature of trade, and that the profits realized from the sales of these properties were properly included in the income of Antoine and Gabrielle Hullmann for the 1964, 1966, 1967, 1968 and 1969 taxation years. ...
T Rev B decision

Allison Janet Craig v. Minister of National Revenue, [1973] CTC 2119, 73 DTC 116

The existence of the first mortgage of $16,000 on the property was not taken into consideration and though the evaluation was $29,000, the assessment on the property was $21,762. ...
T Rev B decision

Jacob Byke, Mitchell Byke and Stella Byke v. Minister of National Revenue, [1972] CTC 2332, 72 DTC 1299

Upon a consideration of the évidence as a whole, I am satisfied that Mary Byke had no funds of her own with which to invest in the purchase of shares of the Tecumseh Hotel and, therefore, the shares transferred to and registered in her name were in fact beneficially owned by her husband Jacob Byke. ...
T_Rev_B decision

Marilou E Shirley v. Minister of National Revenue, [1972] CTC 2341, 72 DTC 1286

And in further consideration of the Vendor granting to the Purchaser the aforesaid easement the Purchaser agrees to permit the Vendor at her own cost to connect such spurlines as she requires at such locations as she desires, without remuneration to the purchaser, leading from the railway line to be erected upon the easement hereinbefore granted. ...
T Rev B decision

Georgia Medical-Dental Building Limited v. Minister of National Revenue, [1972] CTC 2359, 72 DTC 1316

In view of these considerations and findings, it is not necessary to deal with the respondent’s contention that issues not raised in the Notice of Objection cannot be brought up in the Notice of Appeal or even orally at the hearing. ...
BCSC decision

In Re Paul Dennis Bowlen Et Al., [1971] CTC 682, [1971] DTC 5407

In support of his contention, he advanced the several propositions to whose consideration I now turn. ...

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