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Thus, I doubt that section 6(1)(e), properly construed, applies to the automobile here under consideration and I believe that section 6(1)(a) more aptly applies in the circumstances of this case. ...

In reassessing the Appellant for his 1974, 1975, 1976 and 1977 taxation years, the Respondent relied, inter alia, on the following assumptions of fact; (a) During the taxation years under appeal the Appellant was a pharmacist by profession; (b) On December 11, 1973, the Appellant purchased by way of bulk sale agreement from Mr Maurice Berke a pharmacy business under the firm name and style of Berke’s Pharmacy situation at 1101 Ste Catherine street West, in the City of Montreal: (c) As part of the consideration in purchasing the said pharmacy, the Appellant assumed a debt owing by the said vendor Mr Maurice Berke to Mr Leo Berco- vitch in the amount of $37,216, the aforementioned having been attested to in an affidavit annexed to the said bulk-sale agreement as a schedule of accounts payable by the Appellant; (d) On January 2, 1974, Mr Leo Bercovitch signed a waiver and renunciation in favour of the Appellant of his claim for the debt in the amount of $37,216 and forming part of the accounts payable by the Appellant upon the purchase of the pharmacy by way of bulk-sale agreement dated December 11, 1973; (e) the debt owed by the Appellant to Mr Leo Bercovitch in the amount of $37,216 was of a trade or business nature and as such was assumed by the Appellant upon the purchase of the said pharmacy; (f) The Respondent applied the amount of the debt as waived in favour of the Appellant to reduce the latter’s capital cost of class “8” assets as applied to his 1974 to 1977 taxation years; B. ...

MARRIAGE CONTRACT WITH RESPECT TO THE MARRIAGE CONTRACT MADE BEFORE THE NOTARY JACQUES E BEAUDDIN on June 6, 1946, RECORDED AS NUMBER 2411 IN HIS MINUTES — ORDERS the petitioner to pay the respondent a sum of $3,000.00 in consideration of the renunciation by the respondent of the rights conferred on her by the first clause of the third paragraph of the said contract. ...

By applying the same considerations to “The Century 21 Gold Post” and “Real Estate Victoria” I have concluded these publications not to be newspapers and therefore subject to federal sales tax. ...

Following careful consideration of the evidence and all able arguments submitted by both counsel, I must conclude that subparagraph 66.1 (6)(a)(i) is not here applicable, but that subparagraph (ii) applies. ...

His assertion of the value of recreation land lends very little weight to his argument, having consideration to the proximity of the Lake of the Woods area not much further than 120 miles from Winnipeg. ...

A “consideration” portion of the agreement was struck out and initialled by the purchaser, and a casual look at what was deleted from the document indicates that the appellants wanted to obtain a larger down payment. ...

The implied agency arrangements proposed by some appellants failed to take into account the major consideration (the financial obligation) in any way. ...

This is not to say that such a demand to file under subsection 150(2) is a prerequisite in order to conclude that the circumstances indicate an attempt to avoid payment of tax, it is only to say that when such a demand has been issued, I would regard that as sufficient to demonstrate an attempt to evade payment of tax, and to “trigger” the consideration of subsection 163(1). ...

The imposition of a penalty might be taken into consideration by the Board in exercising its discretion on what would be “just and equitable”, but it does not validate the reasons advanced in this application as to why it was “not possible” to file within the required time, which would permit the use of such discretion. ...