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

THE PRESIDENT :—During 1940, 1941 and 1942 the defendant imported into Canada large quantities of canned corned beef from Argentine, Uruguay and Brazil and paid customs duties based on the values at which the goods were entered for customs. On December 16,

THE COURT has heard the witnesses; examined the proceedings and documentary proof; heard the Parties, upon the merits of the present case; and has, upon the whole, deliberated.

THE COURT has heard the witnesses; examined the proceedings and documentary proof ; heard the Parties, by their Counsel, upon the merits of the present case; and has, upon the whole, deliberated.

Cameron, Deputy Judge :—This is an appeal from five assessments made by the Commissioner of Income Tax upon the Appellant in respect of income tax for the years 1937, 1938, 1939, 1940 and 1941, and affirmed by the Minister of National Revenue (hereinafter

THORSON J.:—The suppliant brings this petition of right to recover the sum of $11,144.77 as the total amount of overpayment of income tax alleged to have been made by him in respect of the years 1917 to 1934.

CAMERON, Deputy Judge:—This is an appeal from three assessments made by the Commissioner of Income Tax upon the Appellant in respect of income tax and excess profits tax, for the years 1940, 1941 and 1942, and affirmed by the Minister of National Revenue

THORSON, J.:—During the period between April 1, 1933, and April 29, 1941, the defendant declared and paid dividends to non-residents of Canada on its fully registered 5% cumulative perpetual preference stock. It is alleged that it should have withheld five per