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For the reasons given in that case, and which are to be considered as forming part of this judgment, the appeal herein will be allowed, the decision of the Income Tax Appeal Board set aside, and the assessment made upon the respondent by the Minister will be affirmed. ...

For the reasons given in that case, and which are to be considered as forming part of this judgment, the appeal herein will be allowed, the decision of the Income Tax Appeal Board set aside, and the assessment made upon the respondent by the Minister will be affirmed. ...

For the reasons given in that case, and which are to be considered as forming part of this judgment, the appeal herein will be allowed, the decision of the Income Tax Appeal Board set aside, and the assessment made upon the respondent by the Minister will be affirmed. ...

For the reasons given in that judgment, and which are to be considered as forming part of this judgment, the appeal herein will be allowed, the decision of the Income Tax Appeal Board set aside, and the assessment made upon the respondent by the Minister will be affirmed. ...

For the same reasons as stated in case number 160973 of the Exchequer Court of Canada—and which may be considered as forming part of this judgment—the present appeal is allowed and the assessment here should also be referred back to the Minister to be revised accordingly. ...

Ltd. despite the fact that it was a trading asset and had been considered as such by the old company; (g) After it had changed its name to N.T. ... We considered again that this was a public utility and there was every reason to believe that it should prove to be a conservative investment. ... To this extent that we considered eight dollars ($8) a share to be a proper price.” ...

From this it follows that the undervalue is not decisive of the nature of the transaction but that the character of the recipient must also be considered. If, however, this has to be considered, there is no reason for excluding from consideration any other relevant circumstance. ... The decision in the Julius Bendit case was of course given before the matter of gratuitous transfers of stock was considered in Sharkey (Inspector of Taxes) v. ...

In this case, the income of ‘‘Q and Co.’’ was divided between the various persons who were considered to be partners, and in the proportions agreed upon by them. ... What the rights of the wives and daughters would have been had they been refused entry into the firm, or what they would have taken out in the event of a dissolution is here of no importance and need not be considered. ... But if the participation in profits is only one among other circumstances to be considered, it is wrong then to say that the participation in profits raises a presumption of partnership which has to be rebutted by something else; in such a case all the circumstances must be considered in order to ascertain the real intention of the parties before any conclusion is drawn.’’ ...

M.N.R. case and it would be superfluous to repeat here the arguments and jurisprudence I considered in reaching the conclusions I did in that case. What must now be considered is whether there are any differences in the evidence as to the personal background and apparent intentions of the late Donald F. ...

That was indicated by the fact that the buildings were sold for $200 and therefore the appellant contended that the Board considered the buildings had no value. ... In the determination of that value to the owner various items may be considered and these will vary according to the circumstances of particular cases. ...