FAUTEUX,
J.
(all
concur)
:—This
is
an
appeal
from
a
Judgment
of
the
Exchequer
Court
of
Canada,
dismissing
appellants’
appeal
from
an
estate
tax
re-assessment
made
by
the
Minister
of
National
Revenue
and
levying
a
tax
in
the
net
amount
of
$250,390.60
in
respect
of
the
estate
of
Agnes
Henry
Wilson.
Agnes
Henry
Wilson,
hereafter
also
called
the
deceased,
died,
while
domiciled
in
the
province
of
Quebec,
on
January
26,
1963.
She
was
survived
by
her
husband,
Robert
George
Sare,
and
three
children
of
mature
age.
In
her
last
will
and
testament,
she
made
certain
particular
legacies,
bequeathed
the
residue
of
her
property
including,
inter
alia,
any
property
over
which
she
‘‘may
have
the
power
of
appointment
or
disposal"
and
appointed
as
her
executors
the
appellants
and
her
husband;
the
latter
died
on
September
24,
1965,
and
has
not
been
replaced
as
an
executor.
The
present
litigation
concerns
(i)
the
property
being
the
share
which,
by
his
last
will
and
testament,
executed
at
the
City
of
Montreal
on
December
11,1912,
James
Reid
Wilson,
the
father
of
Agnes
Henry
Wilson,
—
who
himself
died
on
May
11,
1914,
—
allotted
to
the
latter
as
one
of
his
universal
residuary
legatees
and
(ii)
certain
other
property
which,
by
deed
of
donation
inter
vivos,
done
at
the
City
of
Montreal
on
December
17,
1912,
he
gave,
in
trust,
to
the
Royal
Trust
for
her.
At
the
date
of
the
death
of
the
deceased,
the
value
of
the
property
comprised
in
her
share
in
the
estate
of
her
father
was
$986,593.11
and
the
value
of
the
property
given
to
the
Royal
Trust
for
her
was
$113,054.03.
The
issue
between
the
parties
can
be
briefly
stated.
In
computing,
as
he
is
required
to
do
by
Section
3
of
the
Estate
Tax
Act
(1958),
7
Eliz.
II,
c.
29,
the
aggregate
value
of
the
property
passing
on
the
death
of
the
deceased,
the
Minister
included
the
property
mentioned
above
which
he
considered
as
property
coming
within
that
description.
On
appellants’
view,
such
is
not
the
case.
Their
submission
is
that,
in
view
of
the
terms
of
the
will
and
of
the
deed
of
donation,
executed
by
her
father,
the
deceased
was
never,
within
the
meaning
of
Sections
3(1)
(a),
3(2)
(a)
and
58(1)
(i)
of
the
Estate
Tax
Act,
competent
to
dispose
of
this
property.
The
Wall:
After
bequeathing
numerous
particular
legacies,
the
father
of
the
deceased
left
the
residue
of
his
estate
to
his
children
in
equal
shares,
thereby
instituting
them
as
his
universal
residuary
legatees.
With
respect
to
the
share
of
his
daughters,
he
directed
that:
The
shares
of
each
of
my
daughters
shall
be
retained
in
the
hands
of
my
Executors
during
her
lifetime,
and
only
the
revenues
thereof
paid
to
her.
and
dealing
particularly
with
the
share
of
his
daughter,
Agnes
Henry
Wilson,
the
deceased,
he
further
directed
in
the
tenth
clause
:
TENTH:
The
capital
of
the
share
of
my
daughter
AGNES
HENRY
WILSON
(Mrs.
R.
G.
SARE)
shall
be
disposed
of
after
her
death
in
the
following
manner
:
Should
she
die
without
leaving
issue
surviving
her,
one-fourth
of
her
share
shall
belong
to
her
husband,
if
living,
and
the
remaining
three-fourths
shall
belong
to
her
brothers
and
sisters,
in
equal
shares.
Should
she
die
leaving
issue
surviving
her
which
live
to
be
six
months
old,
the
capital
of
her
share
shall
be
disposed
of
after
her
death
in
such
manner
as
she
may
direct
by
Will,
or
should
she
die
intestate
it
shall
belong
to
her
heirs-at-law.
The
donation
to
be
made
by
me
to
THE
ROYAL
TRUST
COMPANY
for
the
benefit
of
my
said
daughter
AGNES
HENRY
WILSON,
shall
be
considered
as
a
payment
to
my
daughter
in
advance
on
account
of
her
share
in
my
estate
&
in
the
division
of
my
estate
the
TRUST
PROPERTY
mentioned
in
said
Deed,
or
the
securities
representing
the
same
at
the
time
of
my
death,
shall
be
considered
as
of
the
value
of
FIFTY
THOUSAND
DOLLARS.
The
Deed
of
Donation:
By
the
deed
of
donation
to
the
Royal
Trust
Company,
made
six
days
after
his
will,
the
father
of
the
deceased
gave
certain
securities
to
the
trustee
upon
trust
to
pay
the
net
revenues
therefrom
to
his
daughter,
Agnes
Henry
Wilson,
during
her
lifetime
and
provided
in
the
fifth
clause
that:
FIFTH:
In
the
event
of
the
said
Dame
Agnes
Henry
Wilson
surviving
said
donor,
she
shall
have
the
absolute
right
to
dispose
of
the
said
Trust
Property
by
her
Will
in
such
manner
as
she
may
deem
advisable,
and,
failing
to
doing,
the
same
shall
at
her
death
pass
to
her
heirs-at-law.
In
the
event
of
the
said
Dame
Agnes
Henry
Wilson
predeceasing
the
said
Donor,
leaving
issue
her
surviving,
any
of
whom
has
attained
or
shall
attain
the
age
of
six
months,
then
the
said
Trust
Property
shall
be
governed
by
the
Will
of
the
said
Dame
Agnes
Henry
Wilson,
and,
failing
a
Will,
the
same
shall
become
the
property
of
her
heirs-at-law.
In
the
event
of
the
said
Dame
Agnes
Henry
Wilson
predeceasing
the
said
Donor,
without
leaving
issue,
or,
leaving
issue,
none
of
whom
attains
the
age
of
six
months,
then
the
said
Trust
Property
shall
be
divided
between
the
said
Robert
George
Sare
and
the
Estate
of
the
said
Donor
in
the
proportion
of
one-fourth
to
the
said
Robert
George
Sare
and
three-fourths
to
the
Estate
of
the
said
Donor,
but,
in
the
event
of
the
said
Robert
George
Sare
being
not
then
living,
then
the
whole
of
the
said
Trust
Property
shall
revert
to
and
form
part
of
the
Estate
of
the
said
Donor.
In
these
extracts
of
the
will
and
of
the
deed
of
donation,
I
have
indicated
in
italics
the
very
event
which,
amongst
others
contemplated
by
the
father
of
the
deceased,
did
actually
take
place.
It
is
common
ground
that
the
provisions
of
the
Estate
Tax
Act
which
are
here
relevant
are
to
be
found
in
the
following
sections
:
3.
(1)
There
shall
be
included
in
computing
the
aggregate
net
value
of
the
property
passing
on
the
death
of
a
person
the
value
of
all
property,
wherever
situated,
passing
on
the
death
of
such
person,
including,
without
restricting
the
generality
of
the
foregoing,
(a)
all
property
of
which
the
deceased
was,
immediately
prior
to
his
death,
competent
to
dispose;
(2)
For
the
purposes
of
this
section,
(a)
a
person
shall
be
deemed
to
have
been
competent
to
dispose
of
any
property
if
he
had
such
an
estate
or
interest
therein
or
such
general
power
as
would,
if
he
were
sui
juris,
have
enabled
him
to
dispose
of
that
property;
58.
(1)
In
this
Act,
(i)
“general
power”
includes
any
power
or
authority
enabling
the
donee
or
other
holder
thereof
to
appoint,
appropriate
or
dispose
of
property
as
he
sees
fit,
whether
exercisable
by
instrument
inter
vivos
or
by
will,
or
both,
but
does
not
include
any
power
exercisable
in
a
fiduciary
capacity
under
a
disposition
not
made
by
him,
or
exercisable
as
a
mortgagee;
The
trial
judge
rejected
as
ill-founded
appellants’
fundamental
contention
that
the
deceased,
Agnes
Henry
Wilson,
was
not
competent
to
dispose
of
the
above
property.
He
considered
that
the
latter
had
survived
her
father
and
left
three
children
of
mature
age;
that,
in
such
event,
her
father
had
directed,
in
his
will,
that
the
capital
of
her
share
shall
be
disposed
of
after
her
death
in
such
manner
as
she
may
direct
by
Wall
and
had
directed
by
the
deed
of
donation,
that
she
shall
have
the
absolute
right
to
dispose
of
the
said
trust
property
by
her
Wall
in
such
manner
as
she
may
deem
advisable;
and
the
learned
judge
held
that
these
were
plain
and
unambiguous
directives
which
vested
the
deceased
with
a
general
power
to
dispose,
by
will,
of
such
property
as
she
saw
fit.
In
support
of
their
appeal
from
this
decision,
appellants’
first
submission
is
that,
on
a
proper
interpretation
of
Section
3(1)
(a),
it
cannot
be
said,
—
as
admittedly
it
has
to
be
found
in
this
case
to
sustain
the
assessment,
—
that
the
deceased
was
immediately
prior
to
her
death,
competent
to
dispose
of
the
property.
They
argue
that
since
the
property
to
be
included,
under
Section
3(1)
(a),
is
all
the
property
of
which
the
deceased
was,
immediately
prior
to
her
death,
competent
to
dispose,
and
since
a
will
has
no
disposing
effect
until
the
time
of
or
after
death,
one
must
conclude
that
a
person,
whose
estate
or
interest
in
property
is
such
as
to
enable
him
to
dispose
of
it
only
by
will
or
whose
general
power
over
it
is
exercisable
only
by
will,
is
not
a
person
immediately
prior
to
his
death
competent
to
dispose
of
it.
Thus,
on
appellants’
interpretation,
Section
3(1)
(a)
contemplates
property
which
a
deceased
was
competent
to
actually
and
effectively
transfer
immediately
prior
to
his
death,
and
not
property
which
is
only
actually
and
effectively
transferred
after
death.
In
my
opinion,
Section
3(1)
(a)
deals
with
the
competency
to
transfer
and
not
with
the
transfer
of
property;
and
the
words
immediately
prior
to
death
in
Section
3(1)
(a)
refer
to
the
point
at
which
a
person
is
competent
to
dispose
of
property
and
not
to
the
point
at
which
there
is,
consequent
to
the
exercise
of
competency,
an
actual
and
effective
transfer
of
property.
Appellants’
interpretation
is
further
conclusively
defeated,
in
my
view,
by
the
provisions
of
Section
58(1)
(i)
which,
collectively
with
Sections
3(1)
(a)
and
3(2)
(a),
operate
to
provide
that
a
person
shall
be
deemed
to
have
been
competent
immediately
prior
to
his
death
to
dispose
of
property
if
the
general
power
enabling
him
to
dispose
of
property
is
exercisable
either
by
instrument
inter
vivos
or
by
will,
or
both.
Doubts
were
cast
by
appellants
as
to
the
applicability
or
effectiveness
of
Section
58(1)
(i)
for
the
reason
that
Section
58(1)
(i)
is
in
Part
IV
of
the
Act,
while
Section
3(1)
(a),
the
taxing
section,
is
in
Part
I
thereof.
Part
IV,
as
its
heading
accurately
indicates,
deals
exclusively
with
Interpretation
and
Application
of
the
Act.
Section
58
defines
various
expressions
found
in
the
Act.
The
opening
words
of
the
section
leave
no
doubt
that
the
meaning
and
effect
which
must
be
given
to
the
expression
general
power
appearing
in
Section
3(2)
(a),
is
the
meaning
and
effect
that
Parliament
ascribed
to
that
expression
in
Section
58(1)
(i).
Appellants
contended
that
their
interpretation
of
Section
3(1)
(a)
is
borne
out
by
Section
3(2)
(e)
which
relates
to
the
legal
system
of
community
of
property
and
which
prescribes
that:
(e)
notwithstanding
anything
in
this
section,
the
expression
in
paragraph
(a)
of
subsection
(1)
“property
of
which
the
deceased
was,
immediately
prior
to
his
death,
com-
pe-tent
to
dispose”
does
not
include
the
share
of
the
spouse
of
the
deceased
in
any
community
of
property
that
existed
between
the
deceased
and
such
spouse
immediately
prior
to
his
death.
It
is
said
that,
in
effect,
this
section
provides
that
when
a
deceased
husband
and
his
spouse
were
in
community
of
property,
the
share
of
the
surviving
spouse
is
not
to
be
included
in
the
property
of
which
the
husband
was,
immediately
prior
to
his
death,
competent
to
dispose.
And
it
is
then
argued
(i)
that
if,
on
the
one
hand,
the
expression
immediately
prior
to
his
death
means
at
the
time
of
his
death,
then,
these
provisions
are
unnecessary,
since,
under
article
1293
of
the
Civil
Code
of
the
province
of
Quebec,
the
husband
is
not
competent
at
the
time
of
his
death
to
dispose
by
will
of
anything
more
than
his
share
in
the
community;
and
(ii)
that
if,
on
the
other
hand,
the
expression
means
a
point
during
the
lifetime
of
the
husband,
then,
since
the
husband
has
the
right
to
dispose
of
the
community
property,
during
his
lifetime,
these
provisions
are
necessary
to
prevent
that,
on
the
death
of
the
husband,
tax
be
exigible
on
the
whole
and
not
merely
on
his
half
of
the
community
property.
Hence,
the
appellants
conclude
that
the
latter
meaning
must
be
given
to
the
expression
immediately
prior
to
his
death.
The
Estate
Tax
Act,
enacted
in
1958
and
coming
into
force
on
January
1,
1959,
governs
the
estate
of
persons
who
died
on
or
after
that
date
and
is
designed
to
replace
the
Dominion
Succession
Duty
Act,
R.S.C.
1952,
c.
89,
which
continues
to
govern
the
estates
of
persons
who
died
prior
to
that
date.
I
agree
that
Section
3(2)
(e)
of
the
Estate
Tax
Act
is
not
really
necessary.
Indeed,
it
had
no
counterpart
in
the
Dominion
Succession
Duty
Act
and,
in
my
opinion,
was
inserted
in
the
Estate
Tax
Act
ex
majore
cautela
to
ensure
that,
in
cases
of
community
of
property,
on
the
death
of
the
husband,
his
estate
would
not
be
deemed
to
include
the
widow’s
community
half.
While,
in
a
loose
sense,
it
may
be
said
that
the
husband
is
competent
to
dispose,
in
his
lifetime,
of
community
assets,
under
the
general
administrative
power
conferred
on
him
by
articles
1292
et
seq.
of
the
Civil
Code
of
the
province
of
Quebec,
he
is
not
free,
not
competent
to
dispose
of
such
assets
in
any
sense
contemplated
by
Sections
3(1)
(a),
3(2)
(a)
and
58(1)
(i)
quoted
above.
The
premise,
on
which
rests
the
second
branch
of
the
dilemma
propounded
by
appellants,
is
not
valid.
In
my
opinion,
these
provisions
of
Section
3(2)
(e)
do
not
support
appellants’
interpretation
of
Section
3(1)
(a).
Appellants’
next
proposition
is
that
even
if
it
can
be
said
that
the
deceased
was
immediately
prior
to
her
death
competent
to
dispose,
she
could
not
appoint
or
dispose
as
she
saw
fit,
for,
notwithstanding
the
unlimited
language
used
in
the
will
and
in
the
deed
of
donation,
her
father
did
not
intend,
thereby,
his
daughter
to
have
the
power
to
dispose
of
the
property
by
her
will
in
any
way
and
to
any
person.
Accordingly,
it
is
said,
she
has
no
such
general
power
as
meets
the
definition
of
Section
58(1)
(i).
This
view,
as
to
the
intention
of
the
father
of
the
deceased,
is
formed
by
the
appellants
on
a
consideration
of
the
directions
appearing
in
the
tenth
clause
of
the
will
and
of
the
provisions
of
the
fifth
clause
of
the
deed
of
donation
which
they
seek
to
interpret
and
rationalize
in
a
manner
consistent
with
the
motives
which,
in
their
view,
prompted
the
father
of
the
deceased
to
so
direct
and
provide.
The
legal
principles
applicable
in
the
determination
of
intention
are
well
known.
With
respect
to
the
determination
of
the
intention
of
a
testator,
the
rule
is
stated
in
Auger
v.
Beaudry
(1919),
48
D.L.R.
356,
where
Lord
Buckmaster,
delivering
the
judgment
of
the
Board,
said,
at
page
359
:
.
.
it
is
now
recognised
that
the
only
safe
method
of
determining
what
was
the
real
intention
of
a
testator
is
to
give
the
fair
and
literal
meaning
to
the
actual
language
of
the
will.
Human
motives
are
too
uncertain
to
render
it
wise
or
safe
to
leave
the
firm
guide
of
the
words
used
for
the
uncertain
direction
of
what
it
must
be
assumed
that
a
reasonable
man
would
mean.
With
respect
to
the
determination
of
the
common
intention
of
the
parties
to
a
contract,
the
rule,
stated
in
article
1013
of
the
Civil
Code
of
the
province
of
Quebec,
is
to
the
effect
that
the
common
intention
must
be
determined
by
interpretation
rather
than
by
adherence
to
the
literal
meaning
of
the
words
of
the
contract
only
if
there
is
doubt
as
to
what
the
parties
intended.
In
view
of
the
plain
and
unmistakable
language
of
the
tenth
clause
of
the
will
and
of
the
fifth
clause
of
the
deed
of
donation
quoted
above,
and
particularly
to
the
italicized
part
thereof,
I
find
no
need
or
justification
to
resort
to
interpretation.
Nor
am
I
able
to
agree
with
the
further
submission
made
in
support
of
this
second
proposition,
that
the
words
in
such
manner
as
she
may
direct
by
will
and
in
such
manner
as
she
may
deem
advisable,
respectively
appearing
in
these
clauses
of
the
will
and
of
the
deed
of
donation,
only
mean
that
the
deceased
could
by
her
will
prescribe
the
manner
in
which
her
children
would
take.
In
the
whole
context
of
the
clauses
in
which
they
are
found,
these
words
are
only
apt
to
describe
the
unfettered
power
which
the
deceased
had
to
dispose
of
the
property
by
will
to
any
person.
Appellants
then
submitted
that
even
if
Mrs.
Wilson,
the
deceased,
could
appoint
or
dispose
to
any
person,
nevertheless
she
never
had
a
general
power
within
the
meaning
of
Section
58(1)
(i),
in
view
of
the
following
provisions
in
the
deed
of
donation
and
in
the
will
:
In
the
deed
of
donation
:—
THE
PRESENT
DONATION,
being
intended
as
an
alimentary
provision
for
the
beneficiaries
herein
named,
the
said
Trust
Property
shall
be,
in
capital
and
revenues,
so
long
as
it
remains
in
the
hands
of
the
Trustee,
incapable
of
being
taken
in
attachment
for
the
debts
of
the
said
beneficiaries,
nor
shall
the
said
annuity
be
capable
of
being
assigned
or
anticipated
in
any
way,
any
such
assignment
or
anticipation
to
be
treated
as
an
absolute
nullity.
In
the
will
:—
TWELFTH
:
I
declare
that
all
the
bequests
herein
contained
are
thus
made
on"
condition
that
the
property
bequeathed
and
the
revenues
thereof
shall
be
exempt
from
seizure
for
any
debts
of
the
legatees
named,
the
said
bequests
being
intended
for
their
alimentary
support.
Thus,
in
both
cases,
the
liberalities
are
declared
to
be
intended
for
alimentary
support
and
the
property
is
made
immune
from
seizure
and,
moreover,
inalienable
in
the
case
of
the
property
donated,
for
the
debts
of
the
beneficiary.
Obviously,
the
provision
of
the
deed
of
donation
becomes
emptied
of
any
purpose
and
object,
at
the
moment
at
which
Mrs.
Wilson
dies
if,
immediately
prior
to
death,
she
disposed
of
the
property
by
will.
In
my
opinion,
in
no
way
could
it
affect
her
right
to
exercise
the
power
enabling
her
to
dispose,
by
will,
of
the
property
donated
in
such
manner
as
she
may
deem
advisable’’.
Nor
could
the
provision
of
clause
twelve
of
the
will
affect
a
similar
power
given
to
her
with
respect
to
the
property
bequeathed
to
her.
A
disposition,
declaring
that
property,
donated
or
bequeathed,
is
intended
to
be
donated
or
bequeathed
for
alimentary
support
and
is,
for
that
reason,
made
immune
from
attachment,
has
always
been
interpreted
by
the
courts
as
not
limiting
the
right
of
the
bene-
fiiciary
to
dispose
of
the
same
as
he
sees
fit,
but
as
having
for
sole
object
and
effect
to
prevent
third
parties
to
acquire
possession
of
the
property
by
attachment,
without
the
consent
of
the
beneficiary.
Nolin
v.
Flïbotte
(1934),
56
Que.
K.B.
315;
Delisle
v.
Vallières
(1939),
77
Que.
8.C.
277;
Caisse
Populaire
de
Lévis
v.
Maranda,
[1950]
Que.
K.B.
249.
Hence,
it
cannot
be
said,
in
my
opinion,
that,
because
of
these
provisions,
Mrs.
Wilson
never
had
a
general
power
to
appoint
or
to
dispose
within
the
meaning
of
Section
58(1)
(i).
Appellants’
last
proposition
is
that
the
father
created
a
fiduciary
substitution,
in
his
will,
with
respect
to
his
daughter’s
share
in
his
estate
and
that
for
this
reason
and
also
because
he
created
a
trust,
in
the
deed
of
donation,
with
respect
to
the
property
donated,
it
is
not
his
daughter,
Mrs.
Wilson,
who
disposed
of
the
property
at
the
time
of
her
death,
but
the
father
himself.
In
the
deed
of
donation,
there
is
admittedly
no
fiduciary
substitution.
As
expressed
in
their
factum,
appellants’
submission
is
that
when,
by
the
deed
of
donation,
the
father
of
Mrs.
Wilson
disposed
of
the
property
to
the
trustee,
he
also
disposed
of
it,
on
his
daughter’s
death
if
she
survived
him,
to
the
person
or
persons
that
she
might
direct
would
receive
it.
And
because,
it
is
said,
the
father
disposed
of
the
property
on
his
daughter’s
death,
she
herself
could
not
dispose
of
it
at
that
time.
In
my
view,
this
submission
is,
to
say
the
least,
repugnant
to
the
unlimited
grant,
which
the
father
made
to
his
daughter
in
the
deed
of
donation,
of
.
.
.
the
absolute
right
to
dispose
of
the
said
property
by
her
Will
in
such
manner
as
she
may
deem
advisable
.
.
.
As
to
the
will,
any
fiduciary
substitution,
which
it
may
be
said
to
contain,
would
be
related
to
and
conditioned
upon
the
happening
of
an
event
other
than
the
one
which
actually
happened
and
with
which,
only,
the
Minister
was
concerned.
I
am
in
respectful
agreement
with
the
learned
judge
of
the
Exchequer
Court
that,
in
the
provision
applicable
to
the
event
which
did
actually
take
place,
there
is
no
fiduciary
substitution.
The
plain
and
unmistakable
language
of
the
direction,
relevant
in
that
case,
rendered
Mrs.
Wilson
free
to
dispose
as
she
saw
fit
of
the
property;
and
those
who
benefited
as
a
result
of
her
will,
received
from
her
and
not
from
her
father.
Even
if
there
were
in
the
will,
as
contended
for
by
appellants,
a
fiduciary
substitution
with
respect
to
the
share
of
Mrs.
Wilson
in
the
estate
of
her
father,
there
would
still
remain
to
be
determined
whether,
by
a
fiction
of
the
law,
—
which
is
open
for
Parliament
to
create
for
purposes
of
federal
taxation,
—
that
share
was
not
property
passing
on
the
death
of
Mrs.
Wilson
within
the
meaning
of
the
Estate
Tax
Act.
The
cases
of
Montreal
Trust
Co.
et
al.
v.
M.N.R.,
[1964]
S.C.R.
647
;
[1964]
C.T.C.
367
and
Wanklyn
et
al.
v.
M.N.R.,
[1953]
2
S.C.R.
58;
[1953]
C.T.C.
263,
to
which
we
were
referred
by
appellants,
differ,
fundamentally
and
in
more
than
one
way,
from:
the
one
here
considered.
Suffice
it
to
say
that
in
the
first
one,
there
was,
in
the
will,
an
effective
fiduciary
substitution
and
that
the
second,
governed
by
the
Dominion
Succession
Duty
Act
(1940-41),
4-5
Geo.
VI,
c.
14,
was
determined
on
consideration
of
certain
provisions
thereof
which
differ,
in
substance,
from
their
counterparts
in
the
Estate
Tax
Act
(supra).
In
my
view,
the
appeal,
from
the
judgment
of
the
Exchequer
Court.
dismissing
the
appellants’
appeal
from
the
estate
tax
reassessment
made
by
the
Minister,
fails
and
should
be
dismissed
with
costs.
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