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(supra) these considerations suggest that the expenditure in question was of a capital rather than of a revenue nature. ... It is true that the document also required the vendor to render certain services for which no separate consideration or part of the sum in question was particularly assigned but to treat the sum as paid in whole or in part for such services would appear to be contrary to the express provision of the agreement. ... I leave the determination of the amount representing the value of this list for the consideration of the Minister, as I have no evidence on which to base even an estimate of the value of the said list of accounts. ...

Alternatively, if the sum of $2,080,000 referred to in paragraph 20 hereof was an amount that would otherwise be included in computing the income of the Appellant for the taxation year 1954, subsection (2) of section 83 of the Income Tax Act directed that it should not be so included since it was the consideration for interests in mining properties acquired by the Appellant as a result of his efforts as a prospector. ... NOW, THEREFORE, THESE PRESENTS WITNESSETH THAT, for and in consideration of the mutual covenants and agreements hereinafter mentioned, the parties hereby mutually covenant and agree as follows: 1. ... The consideration to be paid by the Purchaser shall be the sum of TWO MILLION AND EIGHTY THOUSAND DOLLARS, Canadian Funds, payable forthwith, or as the Vendor shall dictate. ...

FOR AND IN CONSIDERATION OF THE MUTUAL COVENANTS AND AGREEMENTS HEREINAFTER SET FORTH, THE PARTIES HERETO AGREE AS FOLLOWS: 1. ... Whether it turned out to be a profit or not, of course, would depend upon other considerations. ... But the magnitude of a transaction is not an entirely irrelevant consideration. ...

The appellant states that the consideration which the respondent received from Kenneth A. ... The respondent negotiated more than twenty purchase contracts (not merely options), for good and valuable consideration, with owners of nearby patented properties. ...

Hickey’s offer to sell to it 36.17 acres, the consideration being the issue to him or to his nominees of 720 fully paid preference shares. ... Other considerations, however, apply 1 to the profits realized in the sale of the shares in Aldershot Realty Ltd. ... I refused to allow the amendment, but on further consideration, I think that that decision was wrong and that I should have allowed it. ...

The dominating considerations were whether the investment was still a good one and whether the appellant needed money for other corporate purposes. The latter consideration could be the dominating one. I now come to the appellant’s underwriting of the securities issued by Trans-Prairie Pipelines Ltd., hereinafter called simply Trans-Prairie, in 1954. ... It will be time enough to do so at such time as the appellant’s income tax assessments for such years may come before the Court for consideration. ...

The consideration for the transfer was 256 shares of Alsa Holdings Limited. At about the same time, Capitol Petroleums Limited and Mammoth Petroleums Limited were incorporated and Tabor transferred 128 of the shares of Alsa, held by him, to Capitol, in consideration of 800,000 shares of that company, and the other 128 to Mammoth in consideration of 800,000 shares of that company. ... The present case raises the question as to what is meant by ‘‘the day of an original assessment’’ in subsection (4), which in turn involves consideration of what is an assessment within the meaning of Section 46 and when it is made. ...

Dutton and Jennings for an aggregate consideration of $225,000. Foreign Exchange Control Board approval of Messrs. ... McLaughlin offered to pay the appellant company $225,000 in consideration of it surrendering any claim to participate in the York contract. ... The consideration for each remittance in respect to equipment was earmarked very definitely and was approved by the Foreign Exchange Control Board. ...

The obligation to make the payments was undertaken by the appellants in consideration of their acquisition of the right and opportunity to earn profits, that was, of the right to conduct the business, and not for the purpose of producing profits in the conduct of the business.”.. ... It seems, therefore, that the obligation to prepare and deposit the Forest Management Plan was assumed by the appellant company in part consideration, at least, of the acquisition of the licences and the opportunity to earn profits therefrom. ... They claimed to deduct that sum in estimating their profits for income tax: Held, that the agreement to pay the commutation money was in fact part of the consideration for the transfer of the business, that the payment was therefore a ‘sum employed as capital’ and could not be deducted.” ...

On further consideration, I have come to the conclusion that the statement is erroneous in several respects and ought to be corrected. ... Thus the situation now under consideration is very different from that which Lord Thankerton found in the Pioneer Laundry case (supra). ... In that view, the consideration that may have moved him to the actual exercise of his discretion is not a matter for inquiry by the Court. ...