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Statements after the event as to intention at the time of acquisition must be considered along with the objective facts, and such later statements of intention must be looked at very carefully, being self-serving statements. ...

The plaintiff submits that the part of each discount mortgage in excess of the fair market value can be reasonably considered interest, and is therefore deemed to be interest on a debt obligation held by the plaintiff, and not part of the price of the sold property. ...

In the course of his judgment, in addition to the cases already mentioned herein, Urie, J quoted from another judgment of Dixon, J in Sun Newspapers Ltd v Federal Commissioner of Taxation, (1938) 61 CLR 337, where Dixon J discussed the nature of certain sums spent in buying up the competition of a rival, and said at p 363: three matters to be considered, (a) the character of the advantage sought, and in this its lasting qualities may play a part, (b) the manner in which it is to be used, relied upon or enjoyed, and in this and under the former head recurrence may play its part, and (c) the means adopted to obtain it: that is, by providing a periodical reward or outlay to cover its use or enjoyment for periods commensurate with the payment or by making a final provision or payment so as to secure future use or enjoyment. ...

The reimbursement of these expenses cannot be considered as conferring a benefit within the terms of the Act. ...

The taxpayer considered the notice of assessment to be a notice of original assessment of P-Ill, and cannot be faulted for doing so. ...

There are three separate issues to be considered in these appeals: 1. ...

Abromeit's considered business opinion, and his evidence emphasizes this, that to borrow the necessary funds in Europe, chiefly Germany, a clear certificate from the independent auditors was essential. ...

Until the time of the trial the parties had proceeded on the assumption that if a disposition of the cylinders did not occur on June 1, 1985, the rental income received therefrom was to be considered active business income. ...

Finally, Wilson, J. considered as follows the relevant question of reasonableness, at page 11 (D.T.C. 6248; S.C.R. 642-43): It remains to be determined, however, whether the state's intrusion on that privacy interest is unreasonable or, to put it another way, whether it violates the taxpayers’ reasonable expectation of privacy. ...

Because of that, I considered very closely the evidence of the plaintiff and his legal adviser. ...