Before finding that the consideration in an asset sale represented by the assumption by a purchaser of a future reforestation liability should be heavily discounted from the estimate of its value by the taxpayer's auditors, C. Miller, J. stated (at para. 38) that in the jurisprudence there:
"is a common thread ... that shows the tendency of the Courts to be reluctant to impose tax, regardless of the taxing regime, in situations where the amount could be taxed is uncertain or unascertainable."