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It is common ground that the Appellant and MIT are deemed not to deal with each other at arm’s length, [1] and that the Appellant is deemed to have purchased the MIT shareholding for a consideration not greater than its fair market value. [2] Thé reassessment was based upon the Minister’s assumption that the fair market value of these shares at the time of the transaction was $662,000.00. ... I derive from their evidence, and from that of George himself, that he did not simply accept their advice, or an amalgam of it, but that he took into account what they each had to say, and then applied his own business judgment, having regard to both his own knowledge of the company and its business, and the considerations which their advice brought to bear. ...

Counsel further referred to the matter of consideration and the Appellant’s evidence that it was a gift from their father but produced no evidence on behalf of the Company except the statements by the Appellants that that was their belief. ... An assessment under section 160 may be challenged on a number of grounds, including the following: (a) that the transferee gave consideration equal to the fair market value of the property transferred; (b) that the liability of the transferor at the date of transfer was less than that assumed by the Minister. ...

However, it has been decided for assessing purposes to continue to follow the view expressed in that paragraph pending further consideration and the deci- sion of the Federal Court of Appeal. ... I can see no reason why any part of the building should be excluded from consideration. ...

Whether it was in her mind I do not know, but it raises the intriguing prospect of using the provisions of section 111 of the Act, part of which reads: Losses deductible (1) For the purpose of computing the taxable income of a taxpayer for a taxation year there may be deducted such portion as he may claim of- (a) non-capital losses- his non- capital losses for the 7 taxation years immediately preceding and the 3 taxation years immediately following the year; I can appreciate that in her understandable zeal to utilize to the fullest extent the more immediate deduction provisions in the Act, this taxpayer might have tended to reject consideration of the above provision. ... R., [1996] 3 C.T.C. 2316 (T.C.C.)- dismissed In my view, even with the generous areas for consideration expressed in Tonn, supra, these appeals fit more into the category evidenced by Betz, supra rather than by Mastri, supra. ...

The essence of this point was that the Appellant had met the challenge of showing there had been a “reasonable expectation of profit”, not taking into consideration the interest charges, which he regarded as of a different character. ... Even the Appellant’s contention at the trial that she had given some consideration to possible eventual capital gain (a highly debatable prospect) would have required continued financial support from her over a long period and there was no indication she would or could take that on. ...

Despite the sympathy which I feel for this family, I cannot offer relief because based on considerations which are not relevant under the statute. ... The inability to perform must exist even with medication is an important consideration. ...

What is involved here, she said, is a contract in which the consideration is the obligation on the part of the institute to provide the member with those things necessary for a decent life. ... The consideration is of course the congregation’s obligation to provide him with the necessities life. [18] Such an agreement is entirely valid. ...

The appellant suggests that not all the costs incurred, and accounted for by the appellant can be taken into consideration in arriving at the “fair value” of the goods subject to assessment. ... The Appellant submits that the Act, and the ordinary meaning of these words, indicates that the purchase price in this context is the consideration paid by the Appellant to the printer for each circular. ...

I was quite surprised that you did not take child care expenses into consideration in my 1994 and 1995 tax returns. ... Thanking you for your consideration, J.L. Charbonneau, M.D. 41 200 94/06/23 As Exhibit A-3, a report by Dr. ...

Either Morris alone or Morris together with Gold Prop agreed to purchase certain lands from the City for a total consideration of $123,000. ... The following is the entire content of Exhibit R-l: WHEREAS Goldenberg and 739679 are desirous of entering into a joint venture agreement with respect to the purchase and development of lands known as Pond Mills, Blocks K & P (the “Lands”); NOW THEREFORE in consideration of the mutual covenants hereinafter set out and the sum of ONE DOLLAR ($1.00) paid by each of the parties to the other party, the receipt and sufficiency of which is hereby acknowledged, the Parties hereto hereby agree as follows: 1. ...