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In paragraph 16 the testator directed that out of the ‘‘ general income’’ of his estate, including ‘‘the net annual income properly divisible as profits” derived from the Telegram business, there should be paid certain annuities, including annuities in favour of his wife and his two sons and the Hospital for Sick Children. ... Smyrna & Cassaba Ry., [1895] 2 Ch. 596, to which the appellants also refer, where the decision in Bridgewater was followed, an investment made by the defendant company having fallen in value in the market, the amount of the depreciation was debited to revenue. ... I take that to mean that once each year when the i ‘ net annual income properly divisible as profits’’ derived from the business has been transferred to the general income account of the trustees, the latter, under the article, have no further interest in the income of the business for that year; and that it is only the residue of that general income remaining after payment of the specific bequests that is directed to be accumulated for the beneficiary mentioned in the last paragraph of the article. ...

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. ...

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. ...

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. ...

Anaconda American Brass Ltd. 3: The income tax law of Canada, as of the United Kingdom, is built upon the foundations described by Lord Clyde in Whimster & Co. v. ... Solicitors for the respondent: Chambers, Saucier, Jones, Peacock, Black, Gain & Stratton, Calgary. 1 [1963] Ex. ...

(See Osler, Hammond & Nanton Limited v. M.N.R., [1963] S.C.R. 432 at 484; [1963] C.T.C. 164 at 166, per Judson, J.) ... It is of some significance to note in this connection that the lands were entered in the books of the company in an account under the heading ‘‘ Land for Resale’’. ...

.), c. 25—Section 53(4)—S.C. 1955, c. 54— Section 22(1)—Mining and exploration company — Deduction for prospecting, exploration and development expenses. ... To obtain these deductions Falconbridge must show that they come within Section 53(4) of the 1949 income tax amending Act, 1949 (Second Session), ¢. 25. ... J ULLBRIDGE There are four items of expenditure relating to those agreements: Depart Decision Item Period of Expenditure mental in Exche Decision quer Court I. $ 10,512.05 Prior to November 14, 1950, date of incorporation of Gullbridge Disallowed Allowed II. $ 4,953.73 From November 14, 1950, Disallowed Allowed to December 31, 1950 III. $247,243.88 1951 Disallowed Disallowed IV. $ 56,047.26 1952 Disallowed Disallowed The Minister appeals the allowance of the first two items and Falconbridge appeals the disallowance of the second two. ...

The work done on these lengths by defendant was: first, to cut them in lengths of 10’, or 8’; second to creosote them, or dip them in creosoting oils to preserve them against the elements of the weather (for which defendants have a special plant); third, to round them or mill or dress the lumber to the rounded shape; fourth, to bore holes in them in order to insert the pin on which the insulator is placed, and after this work was done, they were sold to the Canadian Pacific Railway at a price, not based on so uch ‘ a thousand feet, but based on so much per hundred “cross arms”. ... Higgins as being an authority which should persuade this Court to hold that ‘‘ produce’’ and ‘‘manufacture’’ as used in the statute presently considered in which neither is defined are synonymous, and I adopt the course of McRuer, C.J.H.C., in Gruen Watch Co. v. ... I view these considerations of both the exemptions in Schedule III to the Excise Tax Act and the items in the Customs Act as being confirmatory of my view that the legislators intended that the words ‘‘manufactured’’ or ‘‘ produced’’ should encompass goods such as the polished marble slabs in question in this appeal. ...