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The Queen, 2009 DTC 912, 2009 TCC 295-- summary under Subparagraph 152(4)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4)- Paragraph 152(4)(a)- Subparagraph 152(4)(a)(i) reliance on professional opinions for technical matter After finding that the taxpayers did not have limited recourse amounts for promissory notes they gave as consideration for the limited partnership units offered with the offering memoranda given the absence of any arrangements for payment of interest on the notes on a timely basis and other deficiencies, Campbell, J. found (at para. 104) that the taxpayers could not be reassessed beyond the normal reassessment period: "I believe they were acting in a reasonable and prudent manner in placing reliance on the various professional opinions before making a decision to invest and should not be held to a higher standard. ...

Accordingly, the film company paid a lump sum of £15,000 to the taxpayer in consideration for his agreement to give up all film work for an 18-month period. ...

Accordingly, the film company paid a lump sum of £15,000 to the taxpayer in consideration for his agreement to give up all film work for an 18-month period. ...

In order for an expenditure to be deductible as an "expense" under s. 20(i)(e)(ii) it must not give rise to an asset (such as the benefit of even temporary insurance) and it must have no consideration other than obtaining the loan. ...

The fact that the purchase was driven, in part, by favourable tax considerations does not detract from the ongoing and commercial nature of the endeavour. ...

The taxpayer then reacquired the property, with a view to reselling it, for consideration that included the extinguishment of Soni's payment obligation to it. ...

"Such agreement was part of the inducement or consideration for the transfer of his shares by Beaupré to the respondent. ...

The Queen, 79 DTC 5186, [1979] CTC 262 (FCA)-- summary under Subsection 212(5) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(5) The non-resident taxpayer, which had acquired from another film distributor the exclusive right for a limited period of time to show certain films on the CBC French-language network, agreed in consideration for a lump-sum payment to supply copies of those films to the CBC and to grant it for the same period of time the exclusive right to show them on its television network. ...

Minister of National Revenue, 91 DTC 696, [1991] 1 CTC 2679 (TCC)-- summary under Subsection 227.1(3) Summary Under Tax Topics- Income Tax Act- Section 227.1- Subsection 227.1(3) In 1981 the taxpayer sold all his shares of the corporation in consideration for a secured debenture of the corporation, but remained on as a passive (and inactive) director. ...

Favouring their deductibility was the significant percentage of a taxpayer's income they represented, their general linkage to the taxpayer's ability to gain or produce income, and policy considerations (the expenditures are incurred as part of the development of another human life). ...