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I am a partner in the law firm of Goodman and Carr, Solicitors for the Appellant herein. 2. ... Pape, [1913] 2 Ch. 469, at 473; Delap v. C.P.R. (1914), 5 O.W.N. 667, at 669. ...

MNR, 2 DTC 655, [1944] CTC 75 (Ex Ct) THORSON, J.:—The appellant acted as agent or correspondent for certain underwriting members of Lloyd’s of London, England, in the writing of Workmen’s Compensation, Employer’s Liability and Occupational Disease insurance, under an annual memorandum of authorization by which the appellant was authorized to accept or reject risks, fix rates of premium, issue policy contracts, collect premiums and settle claims. ...

These two different kinds of electrical power could not be used in the same lines or equipment. 2. During the 1950’s, Ontario Hydro changed the part of its system that had operated on 25 cycle power so that it would operate on 60 cycle power;f [2] and, to do so, had to carry out a very substantial programme of transformation in its own generating and distribution properties, and had to make consequential arrangements with its suppliers and the consumers of its power. 3. ... If he is right in contending that there is no such capital cost, obviously he succeeds without relying on either Section 12(2) or Section 137 (1). 2 +Some small parts continued to operate on 25 cycle power, but these were too remote from the appellant’s plant to have any effect on the situation in this case. 3 * There has been no suggestion that there is any difference between “cost” and “capital cost” in the circumstances of this case. ...

:—This is an appeal from a decision of the Income Tax Appeal Board, dated April 2, 1958, which affirmed a re-assessment, in respect of the appellant’s income tax assessment for taxation years 1949 to 1954, inclusive. ... Usually, these mortgages were passed on by the appellant to his company at the end of each month and, of course, for their total face value of one hundred per cent, 2'. e., the full amount of the principal secured by the mortgage. ... Sections 1 and 2 of the ‘‘Statutory Provisions upon which the Appellant relies’’, hereunder recited, may afford another instance of one Jumping into the fountain to escape the rain. ...

The relevant parts of the Income War Tax Act are parts of Rules 1 and 2 of sec. 1 of para. ... Rule 6 of sec. 2 provides that if a married person described by subpara. ... If the taxpayer is a person described in (a) of Rule 1 of see. 1 and described in (a) of Rule 3 of sec. 2, that is a married person who supported his spouse, a resident of Canada, then Rule 2 of sec. 1 and Rule 6 of sec. 2 are applicable, and no further question arises. ...

The respondent under Rules 2 and 3 assessed the appellant on the following basis. ... The question depends on the construction to be placed on Rules 2 and 3 of sec. 3, para. ... And the persons under Rule 2 are given ‘‘a credit from the tax otherwise payable ‘ They are then subject to the general taxation provision and receive a credit on their tax depending on the amount of their pay and allowances as provided in Rule 2. ...

On May 12, 1967 it claimed exemption for this so-called No. 2 mine for the period of 36 months commencing August 1, 1965. ... The so-called No. 1 mine and No. 2 mine respectively on Lots 9 and 10 and Lots 12 and 13, Range V, in the said township together with their respective installations are illustrated on Exhibit 2. ... The so-called No. 2 mine, which came into production in July 1965, became mined out in July 1967 after about 163,000 tons of ore had been taken from No. 2 shaft area. ...

The Appellants are each a body corporate duly incorporated under the laws of the Province of Manitoba. 2. ... The above subsection was added to the Income Tax Act by Statutes of Canada, 1963, chapter 21, Section 26(1), assented to December 5, 1963, and by virtue of subsection (2) thereof, subsection (2) of Section 138A was made applicable to the 1964 and subsequent taxation years. The contention of counsel for the appellants was, as I understood it, that the authority conferred upon the Minister by Section 138A (2) is a delegation of legislative power. ...

In 1950 the appellant bought Lot 2 and in 1951 built thereon the Fraser Medical-Dental Building. ... Lot 3 and the back of Lot 2 were used as parking places for tenants of the Fraser Medical-Dental Building. ... (c) The traffic pattern of the public does not include Lots 2 and 3, the appellant’s property. ...

While 2 (m), which defines succession, has been taken from section II of the English Succession Duties Act, 1853, dispositions under 2 (m) do not, as they do under sec. ... Far from being ancillary, secs. 2 (m) and 8 (1) are mutually exclusive, just as sees. 1 and 2 of the Finance Act of 1894 are mutuualy exclusive. ... In my opinion the disposition, therefore, cannot be within both sees. 2 (m) and 3 (1). ...