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., [1992] 1 C.T.C. 133, 92 D.T.C. 6174, and in that case the constitutionality of subsection 224(1.2) was considered and found to be intra vires. ... Counsel point out that in Royal Bank, supra, the question which our Appeal Court considered was set forth as follows at pages 534-35 (W.W.R. 6, D.L.R. 262): The simple issue is whether the power granted to the Minister of National Revenue under subsection 224(1) of the Income Tax Act to require payment of a debt owed to a taxpayer to the Minister of National Revenue takes priority over a prior perfected security interest and deprives the secured creditor of the secured position. ... We have considered those submissions and make the following orders: 1. ...

The possibility of selling some of the early acquisitions was considered but not acted upon. ... Lake stated his opinion as follows at page 39 of Exhibit R-10: No matter how one considers this assemblage from the standpoint of the real market, it is our considered opinion there is no way that an experienced dealer could sell this material at fair market in a period of less than ten years and then at varying degrees of discounts. ... Robinson had considered selling new Morrisseau works in 1984 and 1985, and if he had known (as he should have known) the prices being paid by people like the Appellants on the streets of Thunder Bay, I think he would have regarded those prices as too close to his personal formula of paying cash at about 20 per cent to 25 per cent of expected realizable selling prices and, therefore, too risky having regard to the low point in Morrisseau’s personal life and the ease with which his new works were being distributed. ...

Canada (Attorney General) (1999), 46 O.R. (3d) 104, aff’d (2000), 50 O.R. (3d) 728; considered: Joscelyne v. ... Juliar [16]                           As I have recounted, both courts below considered the Court of Appeal’s decision in Juliar, coupled with the chambers judge’s findings, to be dispositive. ... The court deduced the correct price based on “the totality of the evidence”, noting that “[o]nly when the related documents are considered as a whole does the intention of the parties emerge”: paras. 60 and 62.  ...

The Respondent seems to be satisfied that there is a Direction in place. [106]   In those circumstances, in spite of the silence of Bédard J. and the dictum in Exeter, I have chosen to treat the Direction of July 29, 2015, as the latest judicial pronouncement on the matter and considered the cost issue on the motion to strike proper, as per the Direction. [107]   There are also submissions made concerning the application for judicial review. ... I have considered whether one party should be awarded costs in spite of the fact that each side prevailed on one argument. ... That cannot be considered to be a ringing endorsement, as somewhat suggested by the Applicant in his submissions on costs (para 4), of the position taken by the Applicant. ...

Associate Chief Justice Donald Bowman granted the motion, noting that the question of whether the underlying corporate assessment can be challenged by a director has not yet been resolved, and should be fully considered. ... It is not sufficient that a person be signing cheques for the corporation for him or her to be considered a "de facto" director. ... The assessment of a de facto director should be considered only in cases where a person is representing himself or herself as a director. ...

  [33]          This approach was also considered by the Federal Court of Appeal in Hsu v. ... The amount was subsequently returned by the mother further evidencing the fact it was considered a gift. ... Statute-barred Year and Penalties:   [102]      Having found that the Appellant has met the onus of rebutting the Minister’s assumptions above and that the Minister provided no satisfactory proof to the contrary, it stands to reason that the Appellant did not make any misrepresentations as to her income for the years in dispute, and accordingly the 2001 year must by default be considered statute barred under subsection 152(4) of the Act. ...

Michael Weevers, the appeals officer who considered the Appellant’s Notice of Objection. ... The options considered by the Special Committee included the rearrangement of Mohawk Canada’s capital structure and the sale or merger of Mohawk Canada’s Retail Business ... Counsel argues that Mohawk Canada received only shares in Lubes Amalco on August 1 and that past consideration, if any exists, cannot be considered to be consideration received on the amalgamation. ...

As we have seen, the Minister's auditor considered this issue, and determined that the Appellants did not carry on a commercial business, and were therefore not entitled to any of the ITCs. The Minister's auditor never determined whether the invoices on the basis of which the ITCs were claimed met all the other conditions provided for by the relevant Act and Regulations, or whether the expenses in question could be considered personal in nature. ... I doubt whether he considered whether the activities engaged in by the two Appellants could constitute commercial activity even in the absence of a reasonable expectation of profit. ...

That meant that the correctness of the assessment of Continental Bank had to be considered (the issue being whether its gain on the disposition of the partnership interest was a capital gain or income). ...   [62]          The Respondent is now taking the position that the reassessment is based on subsection 55(1) of the Act which, prior to its repeal, read as follows:   55 (1) For the purposes of this subdivision, where the result of one or more sales, exchanges, declarations of trust, or other transactions of any kind whatever is that a taxpayer has disposed  of property under circumstances such that he may reasonably be considered to have artificially or unduly   (a) reduced the amount of his gain from the disposition,   (b) created a loss from the disposition, or   (c) increased the amount of his loss from the disposition,   the taxpayer's gain or loss, as the case may be, from the disposition of the property shall be computed as if such reduction, creation or increase, as the case may be, had not occurred ... Woon argues that the religious practices and beliefs of the shareholders are a relevant consideration in the context of the assumptions considered in their entirety. ...

I considered it a nice extra benefit but I didn't consider it material to my investing. ... He stated that the potential investment in partnership units had an attraction for him because he wanted to diversify his holdings and had not considered up until that time a venture that would get involved in marketing and media and ultimately, the movie business. ... I am satisfied from the evidence that the partnerships were established in the 1995 and 1996 taxation years for the purpose of raising funds for specified purposes, including, in the words of Gamble:... expand the market for its products and services and it was a way in which the company could attract investment dollars and marketing money and it was difficult to raise money on any other basis. [32]     The evidence shows clearly that the Appellants were not involved in a transaction or series of transactions within the meaning of subsection 245(3) since the transaction in question may: reasonably be considered to have been undertaken or arranged primarily for bona fide purposes other than to obtain the tax benefit. ...