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.,.58 Add Profit from sale of Assets 127,990.75 $4,868,906.33 From this there has been deducted for: Interest on borrowings $ 448,542.39 Bond Interest and Expense 609,835.00 Appropriation for depreciation 745,035.92 " for taxes 210,000.00 « for Pension Fund_ 54,679.67 2,068,092.98 Leaving a net profit of- $2,800,813.35 The Company would be assessed for the corporation tax on $2,800,813.35, subject perhaps to some adjustments. ... Now, the question for decision is whether the Surplus Account constituted 4 ‘undistributed income on hand, ‘ ‘ and whether the premium in question was, in fact, paid from that Account. ... If the Surplus Account here were made up of realized profits, and dealt with in that way by the Company, then I think the surplus must be treated as " " undistributed income on hand.’’ ...

Subject to the other provisions of this Part, income for a taxation year from a business or property is the profit therefrom for the year. ’ ’ Section 127, subsection (1) (av) of the Act is as follows: i ‘127(1) (av) a taxpayer’s income from a business, employment, property or other source of income or from sources in a particular place means the taxpayer’s income computed in accordance with this Act on the assumption that he had during the taxation year no income except from that source or those sources of income and was entitled to no deductions except those related to that source or those sources;’’ The Shorter Oxford English Dictionary gives the following meanings of the word ‘ source ’ viz.: “1. ... The following is found in volume 58, Corpus Juris, page 811: ‘ Source. ... C.L.R. 183 at 189, Isaaes, J., said: “The legislature in using the word ‘source’ meant, not a legal concept, but something which a practical man would regard as a real source of income. ’ ’ The word ‘‘source’’ as used in the Act is a correlative term and there can no more be, at its inception, income without a source of income than there can be a child without a mother, and the converse. ...

The Concise Oxford Dictionary defines 1 " news’’ as "‘tidings, new information, fresh events reported,’’ and newspaper” as a "‘printed publication’’. ... I am not satisfied that the legislature had it in mind to impose a sales tax on publications of this kind, which, in the generally received / sense of the word would not be regarded as " " goods ‘‘or’ articles ‘ ‘ produced or manufactured, or imported, for consumption. ...

:—In this matter the plaintiff claims from the defendant company the sum of $1,366.70 said to be due and owing for sales tax under the provisions of section 86 of The Excise Tax Act, R.S.C. 1927, ¢. 179, and amendments thereto, together with interest thereon. ... In my opinion then, with deference, this appeal ought to be allowed and the three questions answered in the negative. ‘ ‘ I think, therefore, that while question 3 of the stated case was answered in the negative, the reasonable interpretation to be put upon the matter was that it constituted a finding that the evidence in the Police Court was insufficient to prove that an assessment had been made. ... The assessment is as follows: " " I, James Joseph McCann, of the City of Ottawa, Minister of National Revenue for the Dominion of Canada, having considered an audit report made by Excise Tax Auditor C. ...

Each bears the brand name as well as the name " " shortening ‘‘ prominently displayed on the labels. ... Graham, another witness for the defendant, also used both liquid and other shortenings and admitted that when she did not use one in liquid form, she used a solid shortening like butter or lard—"‘one of the brands that are sold as shortening. ‘ ‘ Dr. ... Eaton stated that the purpose of hydrogenation is to raise the melting point of the product, and that following hydrogenation ‘‘the product is then commonly called " shortening 9 *’; the peanut oil which is not hydrogenated, he called “a liquid shortening.”’ ...

The Tax Appeal Board, at p. 199, appears to have analyzed the agreement of February 15, 1951, as one for the acquisition by the appellant and Montague of an interest in the Locksley Petroleums Ltd.: ‘ ‘ The substance of the transaction was the acquisition of shares and a royalty interest in Locksley Petroleums Ltd., and deferring payment therefor...”? ... Section 3 of the Income Tax Act defines ‘‘income for a taxation year ” to be ‘‘income for the year from all sources ’ ’ which is a single concept. ... This right to a contingent dividend or dividend is comparable to the contingent right that was the subject-matter of the decision of the House of Lords in John Cronk & Sons Ltd. +. ...

In computing its taxable income for that year, the respondent claimed as a deduction the sum of $16,461.72, paid to the Minister of Hydraulic Resources for the Province of Quebec under the provisions of ‘ 1 An Act to Insure the Progress of Education’’, enacted by the Legislature of the Province of Quebec, 10 George VI, c. 21. ... In computing the amount of the profits or gains to be assessed, a deduction shall not be allowed in respect of (o) any corporation tax, as defined by regulation made by the Governor in Council, paid to the Government of a province or to a municipality. ’ ’ An appeal to the Income Tax Appeal Board was allowed, the Board being of the opinion that the ‘‘ Act to Insure the Progress of Education’’ did not impose a corporation tax, and that the Governor in Council in enacting P.C. 5948 exceeded the powers conferred on him by paragraph (o) of Section 6(1) of the Income War Tax Act, and that it was therefore ultra vires. ...

Counsel for the appellant tendered in evidence the following: ‘ Ex. 1 <A certified copy of the amended Statement of Claim in the proceedings above referred to. ... Then, after considering and rejecting a further claim of the appellant in respect of an alleged infringement of its patent, he eranted the injunction asked for in respect of infringement of trade mark and passing off and continued at pages 350-351: ‘ ‘ The plaintiff is entitled to an accounting of profits from the defendant company or to damages, and may choose which. ... I consider that damages in the amount of $20,000 would meet the requirements of the case and judgment will go for that amount against the defendant company, with costs and fiat for discovery. ’ ’ Counsel for the appellant stressed the fact that at the trial the appellant had elected to ask for an award for ‘‘damages’’ rather than an accounting of profits from the defendant company therein. ...

Slipper 62,500 “ William C. Mainwaring 41,667 ‘‘ (including the share subscribed for by him in the Company’s Memorandum of Association) KR. ... Bruce Robertson 41,667 ‘ ‘ (including the share subseribed for by him in the Company’s Memorandum of Association). 290,000 shares 2. ... Mainwaring ⅙ Mr. Ker ⅙ Mr. Robertson ⅙ and the monies payable to the Company therefor will be paid by the parties in the same proportions.?? ...

The commissioners have taken this view of the facts, and I cannot say they were wrong. ’ ’ On appeal to the Court of Appeal (reported [1924] W.N. 105) the appeal was dismissed. ... The Commissioners have found — and I think it is the fact — that there was here one business... ... Anderson Logging Co., [1917-27] C.T.C. 210, Lord Dunedin said at page 212: ‘ ‘ It may here be as well to say that their Lordships have not the slightest doubt that the judgment of the Supreme Court on the main question was right, being indeed entirely in conformity with the case of Commissioner of Taxes (Victoria) v. ...