CAMERON, J.:—This is an appeal by the taxpayer from a decision of the Income Tax Appeal Board dated October 27, 1952 (7 Tax A.B.C. 177), dismissing his appeal from assessments made upon him in respect of the years 1946 to 1950 inclusive.

THORSON, P.:—This is an appeal from the decision of the Income Tax Appeal Board, sub nom. No. 12 v. M.N.R. (1951), 3 Tax A.B.C. 387, dated February 16, 1951, which, except for two items, dismissed the appellant’s appeal

CAMERON, J.:—This is an appeal from a decision of the Income Tax Appeal Board dated November 21, 1952, by which it affirmed an assessment made upon the appellant for the year 1948. The appeal involves a consideration of the provisions of Section 19(1)

MCRUER, C.J.H.C.:—This is an application by the executors of the estate of the late Henry James McIntyre, for advice. Three questions are propounded for the opinion of the Court. They are as follows:

THORSON, P.:—The appellant appeals against its income and excess profits tax assessments for the years 1941 to 1945 inclusive, claiming that its income was not liable to taxation under Section 4(h) or, in the alternative, Section 4(e) of the Income War

CAMERON, J.:—This is an appeal from a decision of the Income Tax Appeal Board dated April 9, 1953, which disallowed an appeal by the appellant from an assessment made upon it for its taxation year 1950. By that assessment, dated February 1, 1952,

THORSON, P.:—This is an appeal against the appellant’s income and excess profits tax assessment for the taxation year ending December 31, 1945.

THORSON, P.:—This is an appeal from the decision of the Income Tax Appeal Board (1952), 6 Tax A.B.C. 155, dated March 5, 1952, which dismissed the appellant’s appeal from its income tax assessment for 1949. The issue is whether the appellant was a

CARTWRIGHT, J. (concurred in by Kerwin, J.:—These appeals were argued together and raise the same questions relating to taxes demanded on income for the 1947 taxation year. To make clear what these questions are it will be sufficient to refer briefly to

Rand, J.:—The business structure of the respondent consisted of transactions of the following type. A block or unit of selected stocks was purchased and, along with certain money for incidental purposes, deposited with a trust company which I shall call trust