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His assertion of the value of recreation land lends very little weight to his argument, having consideration to the proximity of the Lake of the Woods area not much further than 120 miles from Winnipeg. ...

A “consideration” portion of the agreement was struck out and initialled by the purchaser, and a casual look at what was deleted from the document indicates that the appellants wanted to obtain a larger down payment. ...

The implied agency arrangements proposed by some appellants failed to take into account the major consideration (the financial obligation) in any way. ...

This is not to say that such a demand to file under subsection 150(2) is a prerequisite in order to conclude that the circumstances indicate an attempt to avoid payment of tax, it is only to say that when such a demand has been issued, I would regard that as sufficient to demonstrate an attempt to evade payment of tax, and to “trigger” the consideration of subsection 163(1). ...

The imposition of a penalty might be taken into consideration by the Board in exercising its discretion on what would be “just and equitable”, but it does not validate the reasons advanced in this application as to why it was “not possible” to file within the required time, which would permit the use of such discretion. ...

The Vendor hereby represents and warrants to the Purchaser that: (e) following March 31, 1978 and prior to the Closing there shall not have been any change in the authorized or issued capital of the Company except for the issue of ten thousand (10,000) common shares of the Company to the Vendor for a consideration of One hundred, thirty-three thousand, five hundred and fifty-four dollars ($133,554). ...

In consideration of this payment the respondent was released by the wife “from any further liability” under the said judgment. ...

The fact that the appellant gave valid consideration for the shares he originally acquired in Ark does not necessarily lead to the conclusion that they were acquired as an investment. ...

I deem it useful to quote extensively from Mr Justice Mahoney’s decision wherein he was attempting to determine the pure question of fact of fiscal residence and the consideration and criteria required to determine such residence. ...

(c) A critical consideration of the reasons advanced for the eventual abandonment or the frustration of the stated intention. ...