Robertson
J.A.:
—
We
are
all
of
the
view
that
Mogan
J.T.C.C.
did
not
err
in
concluding
that
the
moneys
received
by
the
appellant
were
on
account
of
income
and
not
capital.
We
have
not
been
persuaded
that
his
appreciation
of
the
facts,
with
respect
to
whether
or
not
the
appellant
possessed
the
requisite
“intention”,
is
anything
but
reasonable.
Accordingly,
the
appeal
will
be
dismissed
with
costs
and
the
appeals
in
the
two
other
related
cases
will
likewise
be
dismissed.
There
shall
be
one
set
of
costs
for
the
appeals.
Appeals
dismissed.
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