Le
Dain,
J:—We
are
all
of
the
view
that
the
appeal
must
be
dismissed
on
the
ground
that
the
tax
imposed
on
the
appellant
under
the
Income
Tax
Act,
RSC
1952,
c
148,
is
not
taxation
in
respect
of
personal
property
within
the
meaning
of
section
86
of
the
Indian
Act,
RSC
1952,
c
149
(now
section
87
of
RSC
1970,
c
I-6).
In
our
opinion,
section
86
contemplates
taxation
in
respect
of
specific
personal
property
qua
property
and
not
taxation
in
respect
of
taxable
income
as
defined
by
the
Income
Tax
Act,
which,
while
it
may
reflect
items
that
are
personal
property,
is
not
itself
personal
property
but
an
amount
to
be
determined
as
a
matter
of
calculation
by
application
of
the
provisions
of
the
Act.
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