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But, moreover, it is not " all professions’’ that can claim the exemption. ... On that point the section enacts: “In any case the decision of the Minister shall be final and conclusive. ’ In this case, the decision of the Minister is to that effect. ... I do not think that the words ‘‘business’’ or "" calling” are used in the section as terms of art intended to define mutually exclusive categories of sources of income but in the popular and ordinary sense and, so used, I think that the words ‘‘profits derived from a commercial or financial or other business’’ are wide enough to include the earnings of a commercial traveller. ...

At the commencement of its 1962 taxation year, appellant then known as Twin Bridges Sand & Gravel Ltd. was carrying on the business of mining, processing and selling sand and gravel principally in the immediate vicinity of Edmonton. ... Solicitors for the appellant: Bishop, McKenzie, Jackson, Redmond & Bentley, Edmonton. ...   [1] [1969] C.T.C. 397, 69 D.T.C. 5263. [2] [1970] S.C.R. 877, [1970] C.T.C. 264, 70 D.T.C. 6199, 11 D.L.R. (3d) 754. [3] [1966] S.C.R. 384, [1966] C.T.C. 150, 66 D.T.C. 5116, 56 D.L.R. (2d) 652. ...

Joubin & Associates Mining Geologists Limited, hereafter referred to as the Joubin company, for a broad general geological survey, over a period of five years, of the mineral possibilities of a section of the unpopulated land through which respondent’s railway ran in the province of Ontario, and which is, essentially, either Crown land or respondent’s property. ...

He subsequently proved as a creditor in the company’s bankruptcy and received two dividends — one in 1959 for $6,119 and the other in 1961 for $3,200. ...

Pour les raisons exprimées au jugement @ quo, Je rejetterais l’appel avec dépens. ...

Whereas the original agreement had called for payment for the appellant’s services in Canadian dollars, the new clause 12.2 provided that, in the event of the appellant financing the construction of its pipeline in whole, or in part, by means of “U.S. pay securities’’ sold prior to December 31, 1964, then each shipper ‘‘shall in its payment of its said monthly cost of service charge ’ ’ substitute United States dollars for Canadian dollars, to the extent provided in the agreement, not to exceed 66% of the monthly cost of service charge. ...

Ltd. and Westcoast Transmission Company Limited, herein referred to as ‘ ‘ the shippers’’, to receive, transport and deliver daily volumes of gas in accordance with the terms and conditions of the contract, by means of a gas transmission system, which the appellant undertook to construct. ...

In 1961, he sought to obtain financial advantages through the acquisition of securities of two companies in a loss position: Sonograph Limited (“Sonograph”) and Sonograph Engineering & Manufacturing Company Limited (“Semco”). ... Here the clear indication of ‘ trade” is found in the fact that the acquisition of the securities was a part of a profit-making scheme. ...

The relevant sections of The Income Tax Act are as follows: “42. (1) The Minister shall, with all due despatch, examine each return of income and assess the tax for the taxation year and the interest and penalties, if any, payable. (2) After examination of a return, the Minister shall send a notice of assessment to the person by whom the return was filed. (4) The Minister may at any time assess tax, interest or penalties and may (a) at any time, if the taxpayer or person filing the return has made any misrepresentation or committed any fraud in filing the return or supplying information under this Act, and (b) within 6 years from the day of an original assessment in any other case, re-assess or make additional assessments. (5) The Minister is not bound by a return or information supplied by or on behalf of a taxpayer and, in making an assessment, may, notwithstanding a return or information so supplied or if no return has been filed, assess the tax payable under this Part. (6) An assessment shall, subject to being varied or vacated on an objection or appeal under this Part and subject to a re-assessment, be deemed to be valid and binding notwithstanding any error, defect or omission therein or in any proceeding under this Act relating thereto. 50. (6) No interest under this section upon the amount by which the unpaid taxes exceed the amount estimated under section 41 is payable in respect of the period beginning 12 months after the day fixed by this Act for filing the return of the taxpayer’s income upon which the taxes are payable or 12 months after the return was actually filed, whichever was later, and ending 30 days from the day of mailing of the notice of the original assessment for the taxation year. ’ ’ The contention of the appellant is that, on the admitted facts, the notice mailed on July 22, 1953, was a nullity because, before it was mailed and at the time it was mailed, it had been decided to conduct a further examination of the appellant’s return. ...

The dispute is as to whether these. amounts were paid " " pursuant to... a written agreement as alimony or other allowance payable on a periodic basis for the maintenance of the recipient thereof’’, these being the words of Section 11(1) (1) relied on by the appellant, It is necessary to state the facts in some detail. ...