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In my opinion the word ‘‘pursuant’’, as used in Section 11 (1) (j), means ‘‘by reason of ” a legal obligation so imposed or undertaken. ...

The expenditures made by the appellant for treating, during the taxation period in question, were $4,206.40, shown in its books as "" treating expenses,'' or "‘treating at hotels,’’ while its disbursements for advertising otherwise were $331.29 for the same period, its total sales for the period being $154,000. ...

The statement therein contained was as follows: " In' compliance with the expressed wish of the annuitant, the date of maturity of this contract is hereby changed from March 24, 1954, to March 24, 1947. ...

It further provided that any surplus over a reserve sufficient to pay the pension due and current needs should be invested in accordance with the provisions of Section 154 of the Insurance Act, R.S.Q. 1964, ¢. 295 (broadly speaking, trustee securities, although investment is permitted in shares of any solvent company incorporated by Canada or any of its provinces which has carried on business for at least five years and is still doing business therein, but only to the extent that investment in such shares shall not exceed one- fifth of the paid up capital of the company issuing same, which would have precluded under this statute investment in the shares of the company which only had $10,000 paid up capital at the time of the first investment and $33,400 paid up capital after the purchase by the fund of the first 234 preferred shares). ... On cross-examination he stated that pension funds ordinarily earn 4% compound interest so that even if only half the fund were invested in deposit certificates at 8% (actually, the deposit certificate eventually purchased in this case earned 7% %) the fund would earn an average of 4% even if the other half were invested in preferred shares and received no dividends. ... In reaching this conclusion, the learned judge was no doubt influenced to a considerable extent by a letter from the company’s chartered accountant to the company prior to the setting up of the plans which began: ‘‘Further to our discussions as to ways of minimizing current income taxes... ” and pointed out that the company could pay $150,000 into a pension plan which would be allowable as a deduction for income tax purposes and result in tax savings of about $75,000 and suggested that the trustees, who might be Messrs. ...

At the time that the loans were made, the respondent acquired over 99 % of Copeland’s issued shares and all of Renown’s issued shares except those that already belonged to Copeland. ...

A-3) is a typical agreement and refers to the appellant as ‘‘ Vendor’’ and the other party as ‘‘Employee’’ and reads: ‘‘WITNESSETH: 1. ...

“EXECUTED by the undersigned on the day of. l 19 ” $248,375.72, from which a sum of $99,587.92 was deducted as “deferred gross profit on instalment contracts’’. ...

It had two options: (a) on a full-time basis, requiring attendance Monday to Friday, inclusive, each week for one academic year September to June, inclusive, or (b) on a half-time. basis, 2 days each week for the same months for > academic years. ...

Clark, 19 T.C. 390, and Barr, Crombie & Co., Ltd. v. C.I.R., 26 T.C. 406. ...

In its context in that section the word ‘ mine” in my opinion has its ordinary meaning and this indeed was the position taken by counsel for both parties, though they differed in their submissions as to the application of the section to the facts. ...