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In 1950 interest accrued to the appellant in the United States on the following Lakehead securities: 31 % Bonds due 4% Demand Notes Jan. 1, 1970 Purchased 200,000 Dee. 12, 1949 250,000 Jan. 23, 1950 500,000 Jan. 26, 1950 4,500,900 Mar. 29, 1950 9,900,000 June 1, 1950 4,500,000 Sept. 21, 1950 At the times of these purchases the appellant’s pipe line was not yet in operation and shares of its capital stock had been sold to the extent of only slightly more than $1,000,000. ... During 1951 the appellant continued to hold the $5,200,000 in 4% Lakehead demand notes and the $250,000 in 344% Lakehead bonds purchased with proceeds of the sale of the appellant’s 4% debentures and the $14,000,000 in 31/2 % Lakehead bonds purchased for the most part with funds representing proceeds of sale of the appellant’s 314% series B bonds. ... This would indicate and satisfy me that the interest which accrued in 1952 on the $5,200,000 in 4% demand notes and the $18,750,000 in 314 % Lakehead bonds was not equalled by the interest payable by the appellant on the borrowed money represented by these investments, and there would thus be some profit in respect of the holding of them. ...

When the second re-assessment was made, this appeal should have been discontinued* [2] or an application should have been made to have it quashed.f [3] This appeal is therefore dismissed, but, having regard to the fact that the second re-assessment appears to have been based on a new view of the facts and not upon a discovery of facts previously known to the taxpayer and not to the respondent, the respondent is ordered to pay such of the appellant’s costs of the appeal as were incurred prior to the setting down of the appeal for hearing. 1 * Reference has also been made to subsection (3) of Section 58 of the Act, which reads as follows: “(3) Upon receipt of the notice of objection, the Minister shall with all due despatch reconsider the assessment and vacate, confirm or vary the assessment or re-assess and he shall thereupon notify the taxpayer of his action by registered mail.” ...

and ‘‘ Anglin-Noreross’’ —under which a new company, West End Plaza Inc., was incorporated to construct and operate that project on the basis that (a) the appellant would transfer the lease for the site to West End Plaza, (b) Property and General Investments and Anglin Noreross would have the responsibility for the financing and construction of the proposed project, (c) the appellant would be employed as manager of the project, when completed, and (d) the appellant would subscribe for 200 shares in West End Plaza at $1 per share, and Property and General Investments and Anglin-Norcross would each subscribe for 400 shares at $1 per share. 3. ...

Exhibit 10 was filed which is a copy of an article from the Canadian Chartered Accountant of July, 1962, entitled ‘‘ Accounting for Finance Charges by Sales Finance Companies’’, wherein, among other things, the author of the article describes these two methods, whose opinion was concurred in by the witness, Mr. ...

Furthermore, Section 98(2) indicates clearly that a notice of appeal \ may be served upon the taxpayer either personally or by being sent by registered mail addressed to him at his last known address and I cannot see why the decision should not be conveyed in a similar manner. ...

The said sale consideration of $176,000 by the provisions of the sale contract was payable and paid over a five-year period in the following amounts: 1958 $ 36,000 1959 35,000 1960 35,000 1961 39,000 1962 35,000 making a total of $176,000. ...

The two cases on which the appellant relied in that connection — M.N.R. v: Valclair Investment Co. ...

Of these two claims, the former ($40,037.50) was waived aside by the Minister and the Appeal Board who, nonetheless, reversed the ministerial disallowance of the latter deduction ($11,095.19) for no other given motive than it ‘‘... was on all fours’’ with appeal No. 319 v. ...

En ce qui regarde le commerce de location de chambres, Trudeau l’exerçait à Montréal, à parts indivises avec un certain René’ Daoust, sous les raisons sociales enregistrées de ‘‘ Alpine Rooms Reg’d”, au numéro 2015, avenue McGill College, puis encore sous celle de ‘‘New Frontenac Hotel and Tavern’’, à 2998 est, rue Rachel. ...

Moreover, the standard printed form of agreement signed by all members of the crew, including the appellant, contained the following provisions: (‘.. in consideration of which services to be duly performed, the said master hereby agrees to pay to the said crew as wages the sums against their names respectively expressed, and to supply them with provisions according to the scale herein.’’ ...