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The Appellant further alleges and the fact is that on his own purchase of the said Hotel and business on August 1, 1973, no specific consideration for “goodwill” was stated or fixed. ... On Question (2) Turning to (section) 14(1), it speaks only of amounts which have become payable to the taxpayer in the taxation year and that the consideration given to the taxpayer will be such that any payment (if any had been made after 1971 for that consideration) would have been an eligible capital expenditure of the taxpayer in respect of the business. The fact is that the taxpayer gave no consideration for allocating capital property in 1973. ...

The respondent asserted: — The appellant by an agreement of purchase and sale sold his residence known for municipal purposes at 765 Woodcrest Blvd in the City of London, in the Province of Ontario, to Sifton Properties Ltd for a consideration of the amount of $46,072.50. — The appellant did not incur any commission expense, legal fees or mortgage discharge fee expense on the sale to Sifton but to the extent that any such expenses were incurred, such expenses were incurred and paid by the said Sifton Properties Ltd. — The expenditures claimed were not amounts paid by the appellant within the meaning of subsection 62(1) of the Income Tax Act. ... As you were advised, the amounts listed above were deductions made for expected future expenses and we are unable to verify that these items were incurred by us in the amounts specified although they were taken into consideration to determine the trade-in value of your home. ...

The limitation imposed by section 67 of the Income Tax Act was considered in Gabco Limited v MNR, [1968] CTC 313; 68 DTC 5210 at 323 [5216] where Cattanach, J stated: It is not a question of the Minister or this Court substituting its judgment for what is a reasonable amount to pay, but rather a case of the Minister or the Court coming to the conclusion that no reasonable businessman would have contracted to pay such an amount having only the business consideration of the appellant in mind. ... I am not at all convinced that the appellant foresaw a sufficiently substantial market for jobs requiring him to provide office facilities that it could be said that he provided the “office” space having regard to business considerations alone. ...

By an agreement dated October 4, 1974, entered into between the appellant and Milne’s Foodliner Ltd, the appellant agreed to sell and the company agreed to buy all the assets of the vendor in the operation of his grocery business, for the consideration as shown as the valuation of the assets appearing in the opening balance sheet of the incorporated company dated the 1st day of November AD 1973. ... Clearly, there was no consideration flowing to Milne’s Foodliner Ltd from the appellant with respect to the alleged assumption of the debt. ...

The assertion by the appellant that his wife was of considerable value as a business assistant to him on the trips could undoubtedly be supported and, had his working companion on the trips been someone other than his wife, his argument that the entire cost of the trips would have been deductible might deserve consideration. This Same consideration, however, does not extend to expenses incurred on behalf of the spouse of a taxpayer, under the circumstances outlined in this case. ...

The Company is to issue 498 common shares of the Company to Melvin Davis for a cash consideration of $84,162. It is my clear interpretation of the evidence, testimony and documents that the cash consideration for the shares themselves was only some $498, at the rate of $1 par value per share. ...

During relatively dry periods, the background level of dust raised by winds and specific local sources such as nearby gravel roads or construction must be taken into consideration. ... The Board accepts that for the three appellants such a possibility existed—relocation of their respective operations—and was undoubtedly given some consideration. For Pantel, it is the view of the Board that the evidence does not support the contention that such consideration was of great substance. ...

.* [1] Under the contract the appellant was required to transport logs belonging to the company to and from different locations on the company’s timber limits in consideration of payments based on distance. ...

In consideration, Great Lakes paid the appellant an hourly rate for each piece of equipment. ...

The question relates to the nature of the profit made by the appellant from the sale of timber on his land and the calculation of the maximum deductible capital cost allowance (in accordance with pargraph 11 (1)(a) of the Income Tax Act, RSC 1952, c 148, as amended, for 1971, paragraph 20(1)(a) of the Income Tax Act, SC 1970-71-72, c 63 as amended, for 1972 and paragraph 1100(1)(f) of the Income Tax Regulations), in computing the appellant’s income for each of the taxation years under consideration. ... The respondent also claimed that, in computing the appellant’s income, he had allowed the maximum deductible capital cost allowance according to paragraphs 11(1)(a) and 20(1)(a) of the Act and paragraph 1100(1)(f) of the Regulations, for each of the taxation years under consideration. ... I therefore conclude that the income from the timber berths on the appellant’s land, which constituted fifty per cent of his income for the 1971 and 1972 taxation years, was income from the operation of a business, as described in his income tax returns for the taxation years under consideration, no matter what the appellant might have to say about it eight and nine years later. ...