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‘ ‘ On December 5, 1931, the inspector of income tax acknowledged receipt of the aforesaid letter, adding: "‘I have forwarded a copy of your letter to the Commissioner of Income Tax, at Ottawa, for his consideration and decision, and shall advise you in regard thereto as soon as possible. ‘ ‘ On December 16, 1931, the Commissioner of Income Tax wrote to the inspector at Winnipeg stating {inter alia): " ‘It would appear from your letter of the 5th instant and stated enclosure that it will be in order to accept a consolidated return for 1931 covering the operations of Western Vinegars, Ltd. for twelve months ended 30th November, 1931, and of Reynolds, Moore & Co. ... After careful consideration of the facts and of the law, I have arrived at the conclusion that the second question must be answered in the affirmative. ...

What the respondent contends is that "‘amount’’ in sec. 16(1) means "‘consideration’’ and the consideration which the appellant received on the reduction and conversion was one share of preferred and one share of common. ...

Minister of National Revenue, [1948] S.C.R. 486, the question of the onus resting on an appellant from an assessment under the Income War Tax Act was under consideration. ... After giving full consideration to the evidence, I have reached the conclusion that the appellant herein has not satisfied the onus resting on him ‘‘to demolish the basic fact on which the taxation rested’’, namely, that the deductible expenses incurred in connection with his business operations, did not exceed $1,500. ...

The contract further provided as follows: "THIS CONTRACT WITNESSETH FURTHER that in consideration of payments made in any other manner than in the manner above indicated, such an annuity shall be paid at the date fixed for the commencement of the annuity as the total payments made (increased at 4 per cent compounded yearly) will purchase at the rate in effect at the date of this contract.’’ ... In consideration of the total payment of $13,639.81 made under this contract, the purchase of an annuity of $1,200.00 guaranteed ten years has been completed.’’ ...

On consideration, I find that contention unanswerable. There is ample legal authority to show that when a Court or other tribunal has to make computations that prima facie require it to forecast the future, it must do what it can with the available materials, and must often work with conventional rules and assumptions; but still if by the time of the computation the event, which ordinarily the tribunal would have to anticipate, has actually taken place, the tribunal must proceed on the actual facts, and can no longer act on artificial rules for measuring the future probabilities as its guide. ... However, different considerations apply to the $17,228.38 reserve allowed and set up before 1947. ...

That consideration appears to me to dispose of the present case. In my opinion, a member of the appellant company, when he pays a premium, makes a rate- able contribution to a common fund, in which he and his copartners are jointly interested, and which is divisible among them, at the times and under the conditions specified in their policies. ... As I see it, the very same conditions are taken into consideration in fixing premium rates as in the case of an ordinary fire insurance company. ...

In the result, therefore, only Item E remains for consideration. The appellant resides at Burlington, Ontario, and is president and general manager of Rolmac Construction Co. ... The question as to whether or not persons and/or corporations are dealing at arm’s length is a question of fact to be determined by a consideration of all the relevant facts and circumstances and the statutory provisions. ... Wright, who was a shareholder, director and secretary-treasurer, was called as a witness on behalf of the respondent, but gave no evidence which would suggest that he or the other shareholders in Nelmar at any time gave independent consideration to the purchase and sale of the properties. ...

As the issues involved are identical in each year, I shall confine myself almost exclusively to a consideration of the appellant’s taxation year 1954. ... In a situation such as this, where the contract of sale includes tangibles and intangibles one or more of which may or may not constitute depreciable property as defined in Section 20(5) (a) of the Act supra and where the parties have failed to set out in the deed of sale the amount expended on each of any of such items, in my opinion the Court is confronted with a special case such as described in Section 20(6) (g) of the Act, which provides: “ (6) [Special cases.I—For the purpose of this section and regulations made under paragraph (a) of subsection (1) of section 11, the following rules apply: (g) where an amount can reasonably be regarded as being in part the consideration for disposition of depreciable property of a taxpayer of a prescribed class and as being in part consideration for something else, the part of the amount that can reasonably be regarded as being the consideration for such disposition shall be deemed to be the proceeds of disposition of depreciable property of that class irrespective of the form or legal effect of the contract or agreement; and the person to whom the depreciable property was disposed of shall be deemed to have acquired the property at a capital cost to him equal to the same part of that amount;” The task of leading evidence which will serve to, figuratively, separate the wheat from the chaff and, also, determine what amount can be reasonably regarded as the sale price of the respective assets concerned is admittedly a difficult one. ... Thus, if the appellant’s aforesaid statement be accepted, the only remaining item requiring consideration is the reasonableness or otherwise of the capital cost of $58,500 which he attributed to his lease. ...

This covered 1,120.41 acres and was for a period of 99 years, the consideration for it being $1,120.41. ... The consideration for it was $13,000 of which the appellant’s share was $6,500, but in this alternative claim it claimed only $80.07, being $1 per acre. ... There were several questions under consideration before the Judicial Committee but I shall refer only to one. ...

Pursuant to the agreement for sale the appellant, among other considerations, gave McCool a demand note for $123,097.34 bearing interest at 5 per cent per annum. ... What the vendor did was to sell his property, for the consideration, in addition to the shares of a price plus interest; that interest is part of the capital cost of the company.” ... For this and other reasons the Department has come to the conclusion that some consideration should be given to the taxpayers whose operations in any year have resulted in a loss, or where there is no taxable profit. ...