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Therefore, in view of the consideration to which I have just adverted, I find that, in Canada, under the Income War Tax Act, 1917, the appellant, a co-operative company, is not exempt from the liability of paying income tax. ...

Attorney-General of Saskatechwan, [1935-37] CTC 277 Sir SIDNEY ROWLATT:—This is an appeal from a judgment of the Court of Appeal for Saskatchewan dated June 6, 1936, ante, p. 271, answering in the affirmative certain questions referred to the Court by the Lieutenant-Governor in Council for hearing and consideration pursuant-to the Constitutional Questions Act, c. 60 of R.S.S. 1930. ...

Griffin on this matter suggesting that there was no evidence to support the findings, they would mention some of the considerations which seem to afford evidence, taken together, upon which a Court could very properly come to that conclusion. ...

As will be seen, the matter involves the consideration of s. 8 of the Assessment Act, R.S.O. 1937, c. 272. ...

In the last referred to case the Supreme Court of Canada had under consideration provisions of the Income Tax Act of the Province of Alberta similar to those contained in the Income War Tax Act (Can.). ...

There were other matters under consideration in connection with a clash as to description of boundaries, which are not present in this action, but in other respects the conditions are identical. ...

Marie [1921] 1 A.C. 288 at p. 290, where Duff J. said: ‘Their Lordships are not disposed to differ from the view pressed upon them that an agreement in order to receive effect under the statute must be very clearly made out; such an agreement, if effective, establishes a privilege in respect of taxation, and the principle is not only well settled, but rests upon obvious considerations, that those who advance a claim to special treatment in such matters must show that the privilege invoked has unquestionably been created.” ...

I would also add that the Officer’s reasoning was consistent with the legislative regime governing the Minister’s discretion to grant relief. [11] On judicial review, the Applicant does not challenge the reasonableness of the Officer’s consideration of this central issue. [12] Instead, before this Court, the Applicant submits that he is a law-abiding citizen and he became a victim of fraud due to his poor English. ...

As consideration, the appellant issued a demand promissory note to Lyrtech in the amount of $1,016,437.   32.       ... As consideration, the appellant obtained a share in future income. The appellant was entitled to 10% of the income from sales of the products resulting from the R&D work and 25% of the income from licences granted with respect to those products.   37.       ...   [32]         Taking all these facts into consideration, I find that Lyrtech exercised a dominant economic influence over the appellant. ...

There are no words modifying or qualifying "purpose" so as to permit consideration whether the acquisition of the debt was a "major" purpose or "motivating" purpose or the "sole" purpose. ... Family considerations played a key role. She wanted to assist Glenwood in which shareholding her husband owned a third interest. ... However, one cannot ignore the fact that a taxpayer's decision that a debt is a “bad debt” must be made on the basis of a recent consideration of all of the known facts. ...