CAMERON, J.:—This is an appeal from a decision of the Income Tax Appeal Board dated May 18, 1954, whereby the appellant’s appeal from an assessment for the taxation year 1952 was dismissed.

CARTWRIGHT, J.:—This is an appeal from a judgment of the Court of Appeal for Ontario [[1955] C.T.C. 170] dismissing an appeal by the Treasurer of Ontario from the judgment of Stewart, J. [[1955] C.T.C. 36] which allowed the appeals of the respondents from