Mahoney,
J.:—We
are
in
substantial
agreement
with
the
reasons
for
judgment
of
the
learned
trial
judge
herein
and
would
dismiss
the
appeal
with
costs.
In
our
opinion,
where
the
business
of
a
taxpayer
is
the
sale
of
franchises
to
others,
the
proceeds
of
those
sales
are
not
receipts
on
account
of
capital
and
section
14
of
the
Income
Tax
Act
is
not
in
play.
In
applying
the
so-called
“mirror
image
rule"'
in
the
circumstances,
the
face
to
be
seen
in
the
mirror
by
the
appellant
is
not
that
of
the
actual
purchaser
of
one
of
its
franchises
acquiring
a
capital
asset
but
its
own
face,
that
of
a
trader
in
franchises.
Section
14
does
not
conclusively
deem
certain
types
of
receipts
and
expenditures
to
be
on
account
of
capital.
It
merely
provides
for
their
treatment
under
the
Act
if
they
are
on
account
of
capital.
Appeal
dismissed.
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