CARTWRIGHT, J.:—The relevant facts out of which this appeal arises are set out in the reasons of my brother Judson. I agree with his view that the question to be determined is what business the appellant did in fact engage in, and that cases of this

Ritchie, J. (all concur) :—This is an appeal from the judgment of Gibson, J. of the Exchequer Court of Canada allowing an appeal from the respondent’s income tax assessment for the year 1962 and holding that the profit which the respondent realized from