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The statute also declares that the rent or other consideration paid or given is to be regarded as paid or given on account of the price of the property. ... Thirdly, in the subsection the expression ‘rent or other consideration paid or given thereunder’ is used in contradistinction to the expression ‘the price fixed by the contract or arrangement’ the former being used with reference to rent or consideration for the use of the property during the lease or hiring and for the option itself while the latter includes the word ‘price’ and appears to me to refer to the consideration to be given for the property under the terms of the contract in the event of the transaction resulting in the property vesting in the taxpayer. ... These considerations lead me to conclude that the words ‘rent or other consideration paid or given thereunder shall be deemed to be on account of the price of the property’ do not bear the interpretation which the appellant’s contention requires. ...

The Court is not concerned with the detailed considerations that were featured in the Taylor case. ... An important case where most of the same considerations were present as in the case at bar, but where the Court found against the Crown, is Sterling Paper Mills Inc. v. ... As emphasized in that case, declarations as to intention must be scrutinized with great care and the main consideration js what was actually done. ...

These considerations indicated that the subdivision should be abandoned and the offer accepted. ... There was first of all no desire to realize the company’s investment in the five acres and no occasion for doing so apart from the considerations which led to the decision to sell. ... In my view the sale of the five acres in these circumstances cannot be dissociated from the trading considerations which prompted the sale of the whole property. ...

His position was that save in cases where there is no consideration at all and cases in which such consideration as is provided for is fictitious or illusory a transaction by which property is acquired for some consideration, however inadequate, amounts in law to a purchase and since here the amount agreed to be paid was substantial, and indeed, in his submission, not far below the fair market value of the land, the transaction must be regarded as a simple purchase of the land by the appellant for the amount settled upon. ... When the result of these transactions from the point of view of the vendor company was under consideration in Petrotim Securities Ltd. v. ... If, however, this has to be considered, there is no reason for excluding from consideration any other relevant circumstance. ...

Turnbull states, however, that he then received nothing from Fell and that he is not sure why such a consideration was inserted. ... Later he says that while it was an outright assignment, there was no consideration and it was done as a matter of convenience. ... If Fell intended to develop the salt rights himself, why did he assign them to Turnbull for a consideration which was never paid? ...

By virtue of such employment or association he was instrumental in having her made a member of a syndicate that, in 1962, acquired the beneficial interest in certain mining “claims” under the mining legislation of the province of Quebec, which claims were promptly resold to a newly incorporated company, called Silverfield Mining Corporation Limited (hereinafter referred to as ‘‘Silverfield’’), for a consideration consisting of shares in that company. ... In the first place, certain: questions arise with reference to Section 83 of the Income Tax Act, the relevant parts of which read as follows: 83. (1) In this section, (a) “minerals” do not include petroleum or natural gas, (b) “mining property” means a right to prospect, explore or mine for minerals or a property the principal value of which depends upon its mineral content, and (c) “prospector” means an individual who. prospects or explores for minerals or develops a property for minerals on behalf of himself, on behalf of himself and others or as an employee. (2) An amount that would otherwise be included in computing the income of an individual for a taxation year shall not be included in computing his income for the year if it is the consideration for (a) a mining property or interest therein acquired by him as a result of his efforts as a prospector either alone or with others, or (b) shares of the capital stock of a corporation received by him in consideration for property described in paragraph (a) that he has disposed of to the corporation, unless it is an amount received by him in the year as or on account of a rent, royalty or similar payment. (3) An amount that would otherwise be included in computing the income for a taxation year of a person who has, either under an arrangement with the prospector made before the prospecting, exploration or development work or as employer of the prospector, advanced money for, or paid part or all of, the expenses of prospecting or exploring for minerals or of developing a property for minerals, shall not be included in computing his income for the year if it is the consideration for (a) an interest in a mining property acquired under the arrangement under which he made the advance or paid the expenses, or, if the prospector was his employee, acquired by him through the employee’s efforts, or (b) shares of the capital stock of a corporation received by him in consideration for property described in paragraph (a) that he has disposed of to the corporation, unless it is an amount received by him in the year as or on account of a rent, royalty or similar payment. (4) Paragraph (b) of subsection (2) and paragraph (b) of subsection (3) do not apply: (a) in the case of a person who disposes of the shares while or after carrying on a campaign to sell shares of. the corporation to the public, or (b) to shares acquired by the exercise of an option to purchase shares received as consideration for property described in paragraph (a) of subsection (2) or paragraph (a) of subsection (3). ... I come now to the second branch of the appellant’s case which is based on the contention that the venture here was fully completed when each of the members of the syndicate received a proportionate part of the shares in Silverfield that represented the consideration for the Fabre Township Claims. ...

Elves in the proportion to the shares held by each in the Company as hereinbefore set out; said royalties to be considered as part of the consideration for the sale, transfer and assignment of the said contract as hereinbefore set out. The Company holding the lease, drilling the well and operating the same for such consideration as may be agreed upon between the Company and a Trustee for the unit holders. ... It was a part of the consideration for the assignment of the lease to Sterling Royalties Ld. that the units of production transferred to the appellants should be charged with the payment of the second instalment of Head’s contract price, if the well came into production. ...

So he told me to make a written submission to the board for their consideration, if, as and when I had title.” ... James A, Whalen, to Vandoo Consolidated Mines Limited for a consideration of $125,000.” ... I did not know at the time who the vendor was, nor did I know what consideration he received. ...

In any event, the sum of $32,000 attributed as the value of the lease by the appellant could not be reasonably regarded as being consideration for the disposition of the lease or as the consideration for depreciable property of a prescribed class and consequently the appellant is deemed by virtue of paragraph (g) of subsection (6) of Section 20 of the Income Tax Act to have acquired the depreciable property comprised in the sale to it by Bruce Sung at a capital cost equal to the sum of $473.50 only, 1.e., the cost of the restaurant equipment. 3. ... The question as to whether this amount of $32,000 can ‘‘reasonably be regarded as being the consideration for such disposition’’ can be determined by the evidence which, on this matter, in my view, indicates that the amount of $32,000 is in fact something less than the true value of this leasehold at the time the transaction took place if consideration is given to the fact that when one of Mr. ... In view of the above, it therefore follows that the amount of $32,000 does not appear to me to be an unreasonable consideration for the disposition of the leasehold interest herein. ...

What the Court is here primarily concerned with is the reasonableness, or otherwise, of the amount regarded by the respondent as the consideration for disposition of the building, within the context of Section 20(6) (g) of the Act. I accept Herman’s evidence that the building was acquired for the purpose of producing income, notwithstanding that it was demolished about 6 years later and that its demolition was one of the options considered (and rejected) when its purchase was under consideration. ... The respondent regarded $419,647 as the portion of the purchase price of $1,850,000 that can reasonably be regarded as being the consideration for the disposition of the building. ...