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Accordingly, on the basis of the pleadings alone, I would dismiss the Notice of Appeal, however, the matter must be also be viewed in the entire context and after consideration of the other grounds relied upon by the Respondent, since in the end, all the Appellant’s arguments lead to the alleged Charter violation.   ...      [32]         Notwithstanding the above, the courts have recognized that while similar considerations may apply to the doctrines of issue estoppel, abuse and collateral attack, the courts have also distinguished the rationale for the doctrines. ...

The first consideration should therefore be to determine the purpose of the legislation, whether as a whole or as expressed in a particular provision. ... As a first step, I propose to be guided by the following sentence quoted above: The first consideration should therefore be to determine the purpose of the legislation, whether as a whole or as expressed in a particular provision. ...

  [34]            Generally, the MNR’s powers of investigation and audit in the Act are the consideration for a self-reporting and self-assessing tax system that depends upon the honesty and integrity of taxpayers for its success (R. v. ...   [41]            This general expression, which introduces the provision under consideration, allows us to situate section 231.2 of the Act in context; the section refers to the MNR’s audit powers, as opposed to its investigative powers. ...

What he did to effect the sale to Iraq is the important consideration. ... Such a consideration is certainly not present in this case. In fact the opposite is true so that the applicability of the Sulley and subsequent judgments should be tempered to some extent for that reason. ...

Une considération sérieuse de l’ensemble de ces faits est nécessaire pour bien établir, au sens de l’article 26(3) des Règles de 1971 concernant l’application de la Loi de l'impôt sur le revenu, le prix de base rajusté des actions ordinaires détenues par les demandeurs au 31 décembre 1971. ... Cette erreur, dans les circonstances, même si elle est légère, doit être prise en considération et la valeur ci-dessus de la totalité des actions de la Compagnie doit être réduite en conséquence à dix millions quatre-vingt-douze mille sept cent soixante-treize dollars ($10 092 773). — super profits générés par les actifs incorporels: $ 806 891 — capitalisés à 15%: $ 5 379 273 Valeur de la Compagnie’. — actifs corporels: $ 3 712 000 — actifs incorporels: $5 379 273 — actif superflu ou excédentaire: $ 1 075 000 —total: $10 166 273 Enfin, il y a lieu de considérer la valeur de l’intérêt minoritaire d’Andrew Yager dont les mille deux cents actions ordinaires vendues correspondaient à quarante-huit pour cent (48%) du capital-actions émis et payé de la Compagnie. ...

Having regard to all the submissions, the Board has concluded that it is appropriate, as in the past, that the storage inventory at July 31, 1977, with interest, be taken into account at the time of consideration of the implementation date for the passing on of the February 1, 1978 increase. ... The consideration moving from the member to the Association was not the outright payment to it of $500 but the deposit with it of that sum. ...

Nowhere does subsection 220(3.1) mention the year of assessment as a relevant consideration.     ... This is another consideration in support of Mr. Bozzer’s interpretation of the subsection ...

In my opinion, the expression "one or more transactions" in s. 8(3) is wide enough to embrace all types of voluntary processes or acts by which property of one person may become vested in another without regard for the reason or occasion for such processes or acts and regardless also of whether the process is undertaken or the act is done for consideration in whole or in part or for no consideration at all. ...

In the Supreme Court of Canada the prime consideration was not the breadth of the authorization but whether the Federal Court of Appeal had jurisdiction to entertain the application. ... In deciding whether to exercise the right last mentioned, he will be gov- [Page 508] erned by many considerations, dominant among which is the public interest and his duty as an executive officer of the government to administer the Act to the best of his ability. ...

Rajchgot's intention, factors such as the frequency of the transactions, the duration of the holdings (whether, for instance, it is for a quick profit or a long term investment), the nature and quantity of the securities held or made, the subject matter of the transaction, whether the securities are heavily financed, the time spent on the activity, motive and the particular knowledge he possessed all have to be taken into consideration. ... Further, the Plaintiff testified that more sales occurred as a result of price considerations, than to meet margin calls. ...