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Nevertheless when the basic assumption relied on in reassessing under the Income Tax Act is that an alleged partnership did not exist between spouses thereby placing the onus on the appellant to establish on the preponderance of the evidence that it did exist one should, in my opinion, be guided by these considerations. ...

In the last paragraph of the reasons for decision, the Board concludes as follows: The Board, after careful consideration of the evidence, concludes that the criteria enunciated in Appeal No. 795 supra, are sufficient to enable the appropriate classification of the goods listed in this reference as well as similar machines. ...

The fact that this will prove more costly to plaintiff is not a fact which should be taken into consideration, as the Japanese yen might have fallen in value in relation to the Canadian dollar in the interval instead of increasing in value, and the decision would have to be the same. ...

The question that remains to be answered is whether on an objective consideration of his particular circumstances, as suggested by Dickson, J. ...

The Minister's reply to notice of appeal sets out the dispute: Statement of Facts — In or about July 1979, the Appellant and his spouse purchased lots 33 and 34 of Stephen Township, consisting of approximately 124 acres of farm land for a total consideration of $107,500.00 (lots 33 and 34 are hereinafter referred to as the “Subject Property”). — In his 1980, 1981 and 1982 Income Tax Returns, the Appellant reported gross rents and expenses giving rise to losses from the rental of the Subject Property. ...

In January 1980 all shares were sold to an unrelated third party for a total consideration of $77,000 allocated $133,000 to the common shares and $44,000 to the class B special shares. ...

In arriving at his estimate O'Brien resorted to market data and income approaches and his estimate that market value as of V-Day was $108,000 included a consideration of the evidence provided by the two approaches. ...

Ltd. 167 shares for $15,586.67 Your cooperation and consideration in this matter is truly appreciated. ...

Even if all these factors were constant this method of valuation does not take into consideration why the comparative sales took place. ...

Tenure would be granted at the discretion of the University after due consideration of my performance. ...