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Attached hereto and marked as Exhibit 1, is a document entitled ‘ Stock Purchase Plan for Employees — Richfield Oil Corporation’, which document comprises two parts, viz: PART I—The Plan’, PART II—Declaration OF TRUST’. 4. ... The Company will make an annual contribution of a sum based upon the ratio of its profits to invested capital which will adjust the total monthly contributions made by the Company to the following schedule: Company Contribution Per cent of Profits as per cent of to Invested Capital Member Contribution Up to but less than 11 % 50% 11 % but less than 12 % 55% 12% but less than 13 % 60% 13% but less than 14% 65% 14% but less than 15% 70% 15 % or over 75% ” The plan further provides that “Invested Capital shall mean the total of all Capital Stock and Surplus (or equivalent) accounts and Long Term Debt of the Company as of the beginning of the preceding calendar year, as reflected in its printed Annual Report to stockholders’’. ... Fordham, Q.C., in the Tax Appeal Board. decision, ‘ ‘ Whatever may be the outcome of this appeal, there is no all- around avoidance of tax; there is simply a shift, as appellant’s counsel aptly put it, in the incidence of the income tax burden. ...

" " 7. The Income War Tax Act, 1917, and amendments thereof are unconstitutional and ultra vires of the Parliament of the Dominion of Canada, in so far as they intend to apply to the defendant, who is a Minister of the Crown for the Province of Quebec.” ... " " Each class is allowed full scope to which upon the natural import of language used it is entitled, the jurisdictions must inevitably overlap, or to use Lord Watson’s expression, ‘interlace’.... ... A tax upon their operations is a direct obstruction to the exercise of Federal powers. ‘ ‘ The stock argument of interference with property and civil rights in the province needs only a passing observation. ...

Le procureur de l’appelant se dit alors désireux de fournir des chiffres plus exacts et produisit l’exhibit A-2, qui se lit comme suit: 2,226,359 pieds carrés à 12^^ $278,294.87 2,226,359 ‘' 6 “ 15 $333,953.85 2,226,359 “ ‘6. “20^ $445,271.80 Le procureur de l’intimé continue: “Q. ... Pour établir une valeur moyenne nous avons additionné le prix par pied carré de toutes les ventes en excluant celles en bas de $0.09 cents du pied carré, que nous croyons ne représentent pas la valeur réelle du terrain au pied carré à cette époque, nous obtenons une moyenne de $0.1114 cents du pied carré, voir détails ci-après:— Vente No. 2 $0.12 “ ‘ ‘ 3 0.12 ‘ ‘ ‘ ‘ 5 0.126 cc ‘ ‘ 10 0.1085 “ ‘ ‘ 1.3 0.108 ‘ ‘ ‘ ‘ 14 0.125 ‘ ‘ ‘ ‘ 16 0.123 ‘ ‘ “ 17 0.0948 Total: $0.925 ~ 8 $0.115 p.c. ... I think we arrived to a price close to $400,000 ‘to be paid ¢ o a period of 6 or 8 years’, I don’t remember again. ...

/48 monthly 48 Autoguild $ 8,800 800(d) Apr. 13/47 10% “ $400 Motors 2nd 13/48 monthly 40 Dominion $ 8,500 400(b) July 1947? ... (See Ex. 2—Supplement, p. 2) (assigned) 47 Andrews, $ 1,500 300(b) Jan. 30/48 5% “ $ 50 Marie 2nd Nov.?/48 monthly * Repath, $ 2,400 250(b) Feb. 20/48 5% “ $150 T. B. and Dec. 15/48 monthly A. ...

In the forms attached to the assessments, it was stated: ‘“You are deemed to be in the business of lending money and purchasing mortgages at a profit, and under section 3(a) and section 4 of The Income Tax Act, to be taxable on the profits therefrom. ’ ’ It appears that the full amount of the tax levied by the assessments in dispute has been paid under protest. ... And at page 260 he said: ‘ ‘ In the present case the finding that the present Respondent was engaged in a concern in the nature of trade is final unless it be shown that there was no evidence to support it. ... What is the line which separates the two classes of cases may be difficult to define, and each case must be considered according to its facts, the question to be determined being—Is the sum of gain that has been made a mere enhancement of value by realizing a security, or is it a gain made in an operation of business in carrying out a scheme for profit-making V ’ In this case, I am unable to find that the appellant so ‘ ‘ organized himself’’ (to buy mortgages at a discount) in a commercial and mercantile way ‘‘or that the capital accretions represented gain made in an operation of business in carrying out a scheme for profit-making’’. ...

Peacock — $110,000 To Isabel Manley — $110,000 To Donald George Ewen — $ 55,000 To Kenneth Ewen — $ 55,000 Total — $550,000 Purcell shall pay $150,000 on account of the said sum of $550,000 by April 15, 1956 as follows:— To Joseph Sedgwick — $ 60,000 To Kenneth W. Peacock — $ 30,000 To Isabel Manley — $ 30,000 To Donald George Ewen — $ 15,000 To Kenneth Ewen — $ 15,000 3. ... Under the 1949 agreement the lenders became partners in the firm of Jack Purcell & Company. 2. ...

The Board has met such a plea on several occasions and it would appear to me to open wide the doors to tax evasion if such an unsupported statement were accepted as meeting and overriding the presumption of validity attributed to an assessment by the Minister. ‘ ‘ The appeal is dismissed with costs. ...

This document, duly certified as follows: « DEPUTY MINISTER OF NATIONAL REVENUE Customs and Excise OTTAWA, February 23, 1950. ... ‘ (Seal) was filed, without further proof, by Counsel for the Crown. In the case of Rex v. ... I should have thought that the concluding words of ss. 9, as added by the amendment, would have had greater clarity if they had read thus: CC shall be received as evidence of the document and of the contents thereof and of the Minister’s signature thereto^ 9 Upon further consideration of the matter, I have reached the conclusion that the ‘ ‘ document, ‘ ‘ which is made evidence, includes the signature of the Minister or in other words everything contained therein, within the delegated power of the Minister. ...

—Sales Feb. 1, 1951 to June 12, 1952—43,500 shares $39,990.00 Less: Cost— 10,000 shares @8^ $ 800.00 33,500 “ @ 71AM 2,512.50 36,677.50 Adjusted Taxable Income assessed $71,823.35 For 1953: Taxable Income previously assessed_. $ 7,417.12 Add: Proceeds from sale of shares of Inland Natural Gas Co. ... Col lieries (Dunsmuir) Ltd. which were acquired through participation with Ross Whittali Ltd. in purchase from Sunray Oils: 1,000 shares $ 9,185.83 Less: Cost at $ per share 3,500.00 5,685.83 Adjusted Taxable Income assessed I 845,7 63.69 As will be noted from the above, during the year 1952 the appellant was assessed for further taxable income on the net proceeds of the sale of St. ... John Oil & Gas Co. Ltd.) For the reasons given in the case of N orman R. ...

Nonetheless, this asserted effect did not trigger so instantaneous a ‘ ‘ follow-up ’ on the part of the executive boards, chosen after both incorporations, of which Harry Topper was not a member. ... & G. Furs, Inc., of which he was the controlling shareholder. He sought to deduct the interest paid to the bank in computing his personal income. ’ ’ (Cf. respondent’s brief, page 14.) ... & G. Furs, Inc., was not used for the purposes of earning his own personal income.” ...