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To the degree that the appellant might rely upon a proposition that the transfer of money (ie, mortgage payments) or that a voluntary transfer as opposed to transfer for consideration (ie, unpaid wages) would be excluded from the application of section 160 of the Act, counsel pointed out that the terminology “property” and ‘directly or indirectly” therein refuted any such argument which counsel for the appellant might raise. ...

If Newco is successful in so developing a portion of the Real Property for such purpose, Ronark, as further consideration for its services as provided in paragraphs 5 and 6 hereof, shall have the option to purchase for a period of two years from the date of this agreement up to 100 of such zero lot line lots from Newco at a price of $6,000 for each such lot, which price shall include the cost of all services (including laterals to the lot line) and any other costs to permit a building permit to be issued for the erection of a single family dwelling upon application by Ronark, all of which costs shall be paid by Newco. ...

In the case under consideration, as soon as the whole consideration entitling the company to a free grant had passed to the Crown, the Crown had no interest. ...

In consideration of $4,000,000 paid to A Ltd, the taxpayer obtained certain rights and privileges to produce and take petroleum substances from lands from which it was already entitled to receive gas. ...

Both parties also submitted for consideration the provisions of section 1801 of the Income Tax Regulations. ...

All issues must be determined by a careful consideration of all the relevant evidence both direct and circumstantial. ... Furthermore, before the shopping centre was built they received an offer to purchase the land, and it was not until 1959, in response to an unsolicited offer, that they sold the company’s shares.Finally, the incorporation of the company was prompted by genuine commercial considerations. ...