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The contract is silent on the duty to “repay” in such an eventuality, and given the carefully structured provisions for repayment from the sales of tickets, and the option considered in the next paragraph, I do not think that an obligation to this effect can be implied. ...

According to the same notes, it was agreed, following discussions, to issue shares and redeem them at the appropriate time, even though it was known that this might be considered an anti-avoidance transaction that ran afoul of the Act. ...

Only in the latter cases can the Crown or the Minister be considered to be bound by a compromise agreement regarding a tax reassessment. [28]            Similarly, the Sifto case dealt with an exercise of discretion by the Minister regarding the penalties assessed by the Agency. ...

First I do not feel bound by the actual purchase price paid for the property in June 1971 because other factors must be considered. ...

For the advances here to be considered income receipts, the Court must be able to find that under and by virtue of his contract of employment the appellant was entitled to commission based income and to advances on possible future earnings from time to time repayable solely out of that source which is to say that the future income if earned was to be the source and security for repayment with no liability to repay if it proved to be inadequate. ...

I indicated to counsel for Defendant at the hearing that I considered this very belated motion to be an abuse of the process of the Court, for reasons which I will set out, and also that I did not believe it should succeed on the merits... ...

This was one of the matters which was litigated before Judge Ferg, however, and can be considered as settled by his judgment. ...

The point was considered, though in relation to a different statute, in Springman v. ...

.), I considered the taxability of a lump sum amount paid by an employer to an employee who moved from one city to another at the employer's request. ...

Moldowan suggests that there may be a number of factors to be considered but we are here concerned only with three: time spent, capital committed and profitability. ...