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Nowhere in the Act is it provided that the word 1 ‘ person ’ ’ where it is used, shall include a corporation. ... The corporate name was printed on the bills in bold type and below it the words ‘‘ Medical Clinic of Dr. ... Cheques drawn on the Company’s bank account were signed “ L. C. Kindree M.D. ’’ beneath which manual signature the words, “Medical Clinic: Squamish Holdings Ltd.” were either stamped or written. ...

In 1959 — The production stage of mining progressed. — The development stage of mining also progressed. — Construction of the smelter buildings was completed. — Construction of the refinery was commenced. — Further construction of the townsite progressed. In 1960 — The production stage of mining progressed. — Both the mill and the smelter were in operation. — The refinery construction progressed. — The construction of the Townsite further progressed. In 1961 — The production stage of mining continued. — Development commenced in a new area of the mine. — The refinery commenced operation. — The construction of the Townsite further progressed. ...

& G. Furs Inc., manufacturers of fur coats and fur garments for wholesale distribution; (b) M. ... & G. Furs, Inc., was not used for the purposes of earning his own personal income. ... & G. Furs, Inc., had no direct relationship and nothing to do with the earning of Mr. ...

That in the alternative if the said gain is found to have arisen from the sale of inventory in the form of land belonging to Bel-Air Builders Company, then no part of such gain could have constituted taxable income in the hands of the Appellant, because it resulted from a slump transaction. ’ ’ and by adding a new paragraph 7 to Part B of the said Notice of Appeal which reads as follows: “That the sale of the residue of the land belonging to Bel-Air Builders Company to the Crown took place before Section 85E of the Income Tax Act came into effect.’’ ... The appellant urges that although the beginning of Rule 115 appears to be permissive, the latter part seems to be mandatory, as it would appear that any amendment‘ ‘ necessary for the purpose of determining the real question or questions in controversy between the parties’’, should be allowed. ... There is no injustice if the other side can be compensated by costs; but if the amendment will put them into such a position that they must be injured, it ought not to be made. ’ ’ In the case of Stewart v. ...

(g) upon her husband’s death to dispose of the estate ‘‘as it may then exist ’ ’ as follows: 1. ... Where a general power to appoint any property either by instrument inter vivos, or by will, or both, is given to any person, the duty levied in respect of the succession thereto shall be payable in the same manner and at the same time as if the property itself had been given, devised or bequeathed, to the person to whom such power is given. ’ ’ Section 31 is complemented by Section 4(1) which reads as follows: ‘ ‘A person shall be deemed competent to dispose of property if he has such an estate or interest therein or such general power as would, if he were sui juris, enable him to dispose of the property and the expression “general power’’ includes every power or authority enabling the donee or other holder thereof to appoint or dispose of property as he thinks fit, whether exercisable by instrument inter vivos or by will, or both, but exclusive of any power exercisable in a fiduciary capacity under a disposition not made by himself, or exercisable as mortgagee.” ...

The foregoing loss was computed in the following manner: Date of Date of Purchase Sale Sale Profit Loss 100 shares—Bristol- Myers Company Sept. 28/61 Mar. 16/64 $5,181.38 300 shares—Manu facturers & Traders Trust Co. of Buffalo Nov. 21/61 Mar. 16/64 $ 3,102.51 208 shares—Atlas Credit Corpora tion Dec. 1/61 Mar. 19/64 3,188.06 200 shares—Marrud, Inc. ... In paragraph 29 of the Notice to Admit Facts the allocation of the appellant’s capital during its fiscal years 1955 to 1964 is tabulated as follows: Mortgages Total Year Receivable Cash Stocks Bonds Capital 1955 $ 29,493.07 $11,021.56 $36,240.42 $86,025.00 $162,780.05 1956 47,878.10 13,248.84 29,607.93 86,025.00 176,759.87 1957 67,844.19 11,757.97 589.28 86,025.00 166,216.44 1958.......... 103,105.99 1,730.21 589.28 86,025.00 191,450.48 1959.......... 113,977.19 1,625.77 589.28 86,025.00 202,217.24 1960.......... 109,743.66 1,887.28 589.28 86,025.00 198,245.22 1961.... 91,161.78 1,463.88 9,096.77 86,025.00 187,747.43 1962.... 84,447.67 5,480.21 50,117.76 2,842.15 142,887.79 1963.... 66,830.79 31,746.88 50,143.48 2,842.15 151,563.30 1964.... 58,383.97 69,643.22 15,717.44 Nil 143,744.63 During its fiscal years 1955 to 1964 inclusive, the appellant received income from the following sources: Mortgages: Year Interest Bank and Bonus Interest Dividends Bonds 1955..... $ 2,724.38 — $ 127.50 $ 812.60 1956 4,355.39 — 1,600.65 4,777.40 1957 4,808.68 — 56.30 2,795.00 1958......... 6,109.82 — 25.82 2,795.00 1959... 9,711.23 — 29.76 2,795.00 1960 10,147.42 — 29.76 2,795.00 1961 9,784.80 — 37.17 2,795.00 1962..... 8,180.86 — 447.09 459.45 1963 8,796.63 — 692.41 Nil 1964.... 7,078.41 $479.64 734.80 Nil $71,697.62 $479.64 $3,781.26 $20,024.45 It is common ground between the parties that Jack Maibach was the guiding force in all transactions of the appellant. ... In Sutton Lumber & Trading Company Limited v. M.N. R., [1953] 2 S.C.R. 77 at 83; [1953] C.T.C. at 244, Locke, J. said: The question to be decided is not as to what business or trade the company might have carried. on under its memorandum, but rather what in truth the business it did engage in. ...

(Ste Beuve). — Pop. Figure: Endommager le portrait d’un rival. — Loc. div.: Portrait en pied, Portrait qui représente la personne tout entière. ... Littré: “... Portrait en pied, portrait qui représente une personne entière. ... Portraits littéraires. ’ ’ Funk & Wagnails: “1. A likeness of an individual, especially of the face, produced by an artist in oils, watercolor, etc., or by photography. 2. ...

Ltd. fit cession de ses biens et entre autres céda à Canadian, < Chemical & Cellulose Co. ... Le paragraphe (f) de la réponse à l’avis d’appel pourrait, jusqu’à un certain point, être invoqué en faveur de cette soumission, lequel paragraphe — dans le but de sauver du temps — il est bon, Je crois, de éter:: “ (f) Le 23 décembre 1957, cette créance fut annulée par Canadian Chemical & Cellulose Co. ... Malone, CSM/os Secretary’’ En ce qui a trait à la lettre Exhibit R-2 précitée, le témoin Malone a témoigné comme suit (p. 49): ‘ ‘ Q. ...

It is thus this contract or arrangement, rather than the ‘ 1 agreement for the sale of the property ’ ’ fictitiously created by the subsection, which is referred to in the expression ‘‘the price fixed by the contract or arrangement’’. Thirdly, in the subsection the expression “rent or other consideration paid or given thereunder ’ ’ is used in contradistinction to the expression “the price fixed by the contract or arrangement ’ ’ the former being used with reference to rent or consideration for the use of the property during the lease or hiring and for the option itself while the latter includes the word “price” and appears to me to refer to the consideration to be given for the property under the terms of the contract in the event of the transaction resulting in the property vesting in the taxpayer. ... (ii)... the capital cost at which the lessee is deemed by subsection (1) to have acquired the property minus the fair market value, at the time the contract or arrangement was entered into, of the part of the property that is not depreciable property; ’ ’ As the property includes both land and improvements thereto and the improvements alone are depreciable property within the meaning of this provision and as the evidence indicates that the value of the land alone at the material time was $9,000 it would appear that the basis for the calculation of the deduction to which the appellant is entitled is $10,500. ...

Mason (Exhibit A8), which letter begins ‘‘Further to our discussions as to ways of minimizing current income taxes ’ ’ etc. and includes the following: Dealing with the current year only, it would be posible, under existing legislation, to do the following: 1) Have C.T.C. ... By letters of August 9, 1966, the Department of Insurance reported to the Minister that the ‘ ‘ allowance ’ designated would be sufficient to meet the proposed benefits (Exhibits A83 and AS—l). ... Those plans were commenced with the letter of April 4, 1966 from Helliwell, Maclachlan & Co. to L. ...