Cameron, DEPUTY Judge:—This is an appeal from an income tax assessment, dated June 16, 1944, in respect of the Appellant’s income for 1941. The taxpayer gave notice of appeal on July 6, 1944, and on September 22, 1944, the Minister of National Revenue

THORSON J.:—The appellant carries on the business of gold mining. In the income tax assessment levied against it for the years 1929, 1931, 1932, 1933, 1935, 1936 and 1937 certain disbursements and expenses made and incurred by it were disallowed as deductions

RINFRET C.J.C.:—Montreal Locomotive Works, Ltd., His Majesty the King, in right of Canada, and the City of Montreal have joined in submitting to the Courts questions of law upon facts admitted pursuant to art. 509 of the Code of Civil

NOTES DU JUGE St-Jacques: — Le jugement de la Cour supérieure a donné lieu à trois appels, dont l’un de la part de la Couronne, l’autre de la Cité de Montréal, et l’appel principal est par la Montreal Locomotive Works Limited.

SIDNEY SMITH (Deputy Judge) : The controversy in this appeal falls within a very narrow compass: the conclusions I have reached and my reasons therefor may be stated with corresponding brevity.

MCPHERSON, C.J.M.:—The respondent company was incorporated under the Dominion Companies Act and is licensed to do business in Manitoba. Its head office is in the Province of Ontario, in which province the manufacture of its product (chewing

RINFRET C.J.C. :—His Majesty the King, in right of the Province of Quebec, claimed from the Montreal Telegraph Company the sum of $38,375.85, with interest from January 12, 1939, as taxes alleged to be due by that company under the Corporation

SMITH, J. (oral) :—I feel that nothing is to be gained by hearing you, Mr. Locke, on the other points. I am sorry if I appear to be rather firmly against you, Mr. Clearihue. We had the pleasure of hearing you four days before this in the

THORSON, J.:—This appeal from the assessments for income and excess profits tax for the taxation years ending January 31, 1940 and 1941, is brought by the appellant because certain amounts of the salaries paid to its executive officers were disallowed as

THE PRESIDENT :—With one difference, the issues in these two cases are similar to those in The King v. Weddel Limited, in which judgment for the plaintiff has just been given. In each case, the defendant during 1940, 1941