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As noted in paragraphs 1.13 and 1.14 of the Statement of Agreed Facts, the Minister in issuing the reassessments considered that the actual amount of the deemed dividend was $419,890 and $173,304 for the 1993 and 1994 taxation years respectively which amounts were grossed up by 25% pursuant to paragraph 82(1)(b). [18]            In order to arrive at these amounts, the Minister computed the deemed dividend by reference to the fair market value of the Leader shares (the "subject shares") which has been agreed to be $673,310. ...

These, then, are the basic concepts to which an organization’s purposes and activities must relate in order to be considered charitable. ...

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. ...

Any standby period occurring after commencement of operations in Jordan will be considered an operations period insofar as surcharge computations are concerned. ...

In those cases, Rogers considered these expenses were unnecessary, unjustified or unreasonable ...

Grader, I was unfavourably impressed by his otherwise unsupported statement to the effect that he considered the United Century had deliberately kept down the attendance at the leased premises in order to attract greater audiences to the two other moving picture houses owned by that company, particularly when it is in evidence that the United Century had occupied the leased premises for seven or eight years and there is no evidence that any similar complaint was ever made during that period. ...

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. ...

By letter dated January 13, 2000, the Minister advised TCPL that he considered the notices of objection invalid. ...

Whether or not such an inference can be read into subsection (5(1) is a matter of interpretation, which must be considered in the general context in which subsection (5(1) is found. ...

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. ...