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I must also take into consideration the fact that the appellant encountered many difficulties at the Aquarium Inc restaurant. ...

Je prends en considération le fait qu’il existait des lots qui se vendaient à $0.05 le pied carré dans le parc industriel et aussi le fait inexpliqué d’une trop grande différence entre le montant du prix de disposition de $0.31 le pied carré et celui de $0.05 fixé par le Ministre. ...

Decision Chairman Snyder, also taking into consideration the percentage of work in relation to the volume of sales, assigned a value of $25,000 to the goodwill. ... The assets of A H Roy & Associates could not be taken into consideration in evaluating the goodwill. ... Could this relationship, which was an asset, be taken into consideration in determining the existence and value of the goodwill of Raymond Ducharme et Associés Inc? ...

We have calculated that our net pre-tax yield on this 7% Income Bond is 7.75%, i.e. after taking into consideration the Income Tax benefits and after deducting our cost of funds. ... He referred also to the reasons for judgment of Rand, J, in the Supreme Court of Canada in the matter of a reference as to the validity of Section 6 of the Farm Security Act, 1944, of the Province of Saskatchewan, reported in [1947] S.C.R. 394, where, at p 411, he states: “Interest is, in general terms, the return or consideration or compensation for the use or retention by one person of a sum of money, belonging to, in a colloquial sense, or owed to, another.” ... In the instant appeal, the acceptance of corporate shares as a part of the total consideration for granting a loan was integrated with the main business activity of the appellant—the loaning of funds. ...

Those personal consequences, when considered with the act made and the type of business carried on, are only a secondary consideration. The principal consideration is whether the legal fees were incurred to preserve and maintain the business. ...

This fact has been given consideration in this Final Estimate of Value. For tax purposes, the in-use value to the owner, which apparently is reflected in Mr McGough’s appraisal, is not an acceptable consideration of what constitutes fair market value. ...

The payment was made in consideration of a release from further obligations under the terms of the order of His Honour Judge Alfred Watts, QC. ... Mr Justice Locke at 96 and 1046 respectively stated: (Lump sum settlement) On June 30, 1950, when the child born of the marriage was less than eleven years old, the appellant made an arrangement with his wife whereby, in consideration of a sum of $4,000, she purported to release him of any further liability under the judgment. ...

The taxpayer does not believe that the Minister has given proper consideration to all the facts and is wrong in his determination of V-Day value by at least $40 per share. ... Mr Aldridge was of the opinion that if consideration were given to optimistic industry forecasts at December 31, 1971 (rather than some of the more modest forecasts also available and referenced by him), a purchaser might be willing to pay the $40.14 per share (roughly the mid-point between $37.50 and $43) which had been used in assessing by the Minister. ...

However, since the appellant filed the cheque by which he paid the said amount of $700 to his partner, and since subsection 9(2) of the Tax Review Board Act provides that “appeals shall be dealt with by the Board as informally and expeditiously as the circumstances and considerations of fairness will permit”, the Board accepts the evidence despite its weakness. The Board accordingly allows the appeal on these points. 4.3.3 Further, the appellant compiled his income by the cash receipts and cash disbursements system, whereas under the Income Tax Act he should have compiled it by the fiscal year system, that is, taking into consideration accounts receivable and accounts payable at December 31 of each year. ...

All are in consideration of a payment to the appellant of a comprehensive fee determined prior to entry into the contract. ... Some further facts are relevant to a consideration of this question. The service contract was called an “Extended Warranty Agreement”. ...