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As partial consideration for the sale of all its properties, Serin (U.S.) received interest-bearing promissory notes the values of which at the date of liquidation was reflected by their principal amounts as follows: The contents of this table are not yet imported to Tax Interpretations. 6. ...

In affirming his judgment in the Supreme Court of Canada, Cartwright, C.J. said at page 498 (C.T.C. 164, D.T.C. 5098): After a consideration of the arguments of counsel and the authorities to which they made reference I find myself so fully in agreement, not only with the conclusion of the learned Exchequer Court judge but also with his reasons, that I am content simply to adopt them. ...

Even permanency of abode is not essential since a person may be a resident though travelling continuously and in such a case the status may be acquired by a consideration of the connection by reason of birth, marriage or previous long association with one place. ...

Dickson, J. suggests the consideration of some criteria, although he cautions that his list of criteria is not exhaustive. ...

Its effect is to substitute for an existing contract a new contract between the same or different parties, the consideration for which is the mutual discharge of the old contract. ...

It must be noted that in agreeing with most of the respondent's disallowances, the Court has taken into consideration the relatively small gross revenues realized by Pearl-Anne's tax preparation business ($4,350 in 1987, $6,110 in 1988 and $7,185 in 1989) and the fact that the respondent has allowed numerous other deductions which were claimed. 4, With respect to the real estate operations carried on by Pearl-Anne (a) The respondent has disallowed the following amounts claimed as "Advertising and Promotion”, namely $1,041 in 1987 (of an amount claimed of $1,320.92), $2,516.16 in 1988 (of an amount claimed of $3,190.16) and $2,877 in 1989 (of an amount claimed of $2,877). ...

On the one hand, account must be taken of the rebuttable presumption that a corporation’s income is business income if that income derives from an activity consistent with its object, and, on the other hand, consideration must be given to the scope of the corporation’s activities which confirms or rebuts this presumption. ...

It is, however, vital that financial transactions be arranged with due consideration to the results thereof from a tax point of view. ...

The appellant’s own learning curve of running a breeding and racing operation by himself must also be factored into the consideration of the Court. ...

A consideration of statements in articles of incorporation regarding the objects of the corporation or restrictions on the businesses it may carry on is not helpful. ...