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The considerations prompting the transaction may be of such a business nature as to invest it with the character of an adventure in the nature of trade even if there is no intention of making a profit on the sale of the purchased commodity. (7) The fact that the transaction is totally different in nature from any of the other activities of the taxpayer and that he has never entered upon a transaction of that kind before or since does not, of itself, take it out of the category of being an adventure in the nature of trade. (8) It is not essential to a transaction being an adventure in the nature of trade that an organization be set up to carry it into effect or that some operation be performed on the subject matter of the transaction to make it saleable. ...

During years previous to the taxation years in question here, namely 1981, 1983 and 1984, Jecco had advanced certain moneys to one Robert Owen Edwards ("Edwards') who had failed to repay the moneys or to bring the enterprises to successful positions so that profit-sharing could be realized as a consideration of the Jecco advances. ...

All of those objective considerations and the concerns that I expressed about the vagueness and indefiniteness of the taxpayer's evidence concerning his plans to continue in the cattle business lead me to conclude that the property was acquired by this taxpayer with the intention of changing the zoning and selling it at a profit, which he did. ...

—all out of consideration and friendship apparently, and with no monetary return at all, should now end up liable for the amount at issue here. ...

On the one hand, with regard to the description of the amounts which were taken into consideration by the caisse in order to arrive at its sale price, it is in agreement with the evidence and does not contradict the Deed of sale. ...

It is my view, based on my appreciation of the testimony and evidence provided at this trial, that these appellants were not dealt with unfairly or harshly, but rather generously and with consideration by the respondent. ...

Fine's family services and the value thereof were consideration for the funds given to her by Mr. ...

It seems to me a significance factor, whether one be talking about the hobby farmer or the part time farmer, is a consideration of whether or not the business is being carried on on a commercial basis with a determination to make the business profitable as soon as possible. ...

Consideration for the loan had been given in the form of a ten per cent bonus of net income and it was suggested that this was superior to an interest factor which might have been attached to the note representing the loan. ...

In so far as the goods were sold for use by food wholesalers, the Board seems to have given no consideration to the extended definition of manufacturer or producer in subsection 2(1) of the Excise Tax Act. [4] With regard to sale to and use by both wholesalers and retailers in the food distribution chain, the decision of this Court in Hobart Canada Inc. v. ...