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I cannot see how these expenses can be considered in the same category as the expenses which were under consideration in the M P Drilling case. ... Since I cannot delineate in quantum between the housekeeping expenses and the incorporating expenses as mentioned previously, all shall be considered as one with the result that judgment shall go dismissing the appeal. ...

But all these elements have an effect on the price of the shares on the stock exchange, and no doubt they were fully considered by the purchasers of the stock at the then prevailing prices. ... I considered the apparent board lot trades during 1971 as the basis for the calculation. ...

Professor Laskin’s views expressed in 1960 should not be regarded as altogether considered. ... But if the tax is considered a tax on property the Attorney-General is no better off. ...

The appellant’s submission, briefly stated, is that the term “warrants” for tax purposes should be considered in the same light as shares. ... He had seen Exhibit A-2 and decided with his partners in 1971, 1972 and 1973 that warrants could be considered in the same investment category as common shares and on the recommendation of Sceptre, the appellant purchased the warrants. ...

He made numerous calculations to his recapitalization of sales and earnings to “normalize” them and,- after arriving at what he considered in his opinion to be the weighted average normalized net income of $38,820, he capitalized it at 25% and valued all the shares of the company at $155,280 at December 29,,1971—or a share value of $77.64. ... All things considered, I am of the view that the value of the shares on Valuation Day would be more reasonably stated to be $55 per share considering all the factors which both experts put forth. ...

It is this proposition that must now be considered. In my opinion this issue can only be framed in terms of jurisdiction. ... According to the applicant, a seizure, under subsection 231(1), cannot be made elsewhere than at the taxpayer’s place of business and it cannot be made, either, when the objects to be seized have already been seized under the Criminal Code: in that view, the seizure was tainted with two irregularities and should be considered to be invalid. ...

In cases of this kind also, judges have frequently held that while the oral evidence of the taxpayer in court must be considered, his actions at the time of the transaction are often of much greater weight than his oral statements made long afterwards. ... He freely admitted at least one fact that might be considered detrimental, that he had continued to pay his wife a salary of $8,000 a year through all the years of her illness, though she was unable to do any work. ...

In this, three aspects may be considered: 1. The situation where there are only two sources of income, one of them being farming. 2. ... In my view, it should be emphasized that this concept provides only one of the indicia, the weight to be given to which will vary with the evidence adduced in each case. and Without attempting in any way to exhaust the possibilities, some of those criteria which might be considered are the relative amounts of capital investment in the respective sources, the reasonableness of his expectation of profit therefrom, the amounts of gross income and of net income derived from each source, the proportion of time spent in each day by the taxpayer in respect of each source, and the prior history of the respective sources in respect of amount of income generated. ...

The Parties hereto agree that the clients or customers of the Vendor and their files as set out in Schedule “A” attached hereto shall remain the sole and exclusive property of the Vendor and are not to be considered as part of this transaction and shall be serviced by the Vendor and he shall be entitled to all commissions paid thereon. ... The result is, having considered the facts of this case, and having read the Cumberland Investments Limited case several times, I have concluded that the expenditure made by Mr Moreau in 1973 in connection with his acquisition from Mr Bellehumeur was an outlay within the meaning of paragraph 18(1)(b) of the Income Tax Act, SC 1970-71-72, c 63, as amended, and not within paragraph 18(1)(a). ...

A secretary, provided by the NBTF, shall be a non-voting member. 36.04 A teacher granted sabbatical leave shall be guaranteed the same or equivalent position on returning to that School District. 36.05 Subject to 36.06, teachers on sabbatical leave are considered to be under full contract with the Board of School Trustees and therefore retain full status and receive all the benefits that any other teacher would receive. 36.06 The sick leave provisions of this Agreement shall not apply to those on sabbatical leave; however, those teachers on sabbatical leave shall not lose their accumulated sick leave. 36.07 No teacher serving on the Sabbatical Leave Committee shall lose salary, sick leave benefits or pension benefits due to an absence or absenses from school under this Article. ... The appellant’s application was considered along with others and subsequently he was orally advised by Mr Kingett (a voting member of the Sabbatical Leave Committee) that he was awarded Sabbatical leave starting at the end of the 1973-74 academic year. ...