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., said: ‘ ‘ The question for decision is, therefore, whether said profit was capital accretion, or, income subject to tax. ...

The character or nature of the transaction must be viewed in the light of the circumstances under which it was embarked upon and its surrounding facts. ’ ’ The decision was affirmed by the Supreme Court of Canada. ...

Manning for her own use absolutely. ’ ’ The testator appointed his three children Harold Ernest Manning (the appellant herein), Luella Muriel Manning, and Doris Anita Manning as executors and executrices of his said will. ...

As I have pointed out, the determination of whether a child is ‘‘a child qualified for family allowance ’ ’ within the meaning of the statutory definition depends on the status of the child in the last month of the taxation year in which the expression is sought to be applied, but it is obvious that the determination of whether a child was a ‘‘child not previously qualified for family allowance’’ within the meaning of the opening words of the section cannot depend on a similar test. ...

C.R. 70 at 80; [1957] C.T.C. 32 at 42, Thorson, P., a former President of this Court, had this to say: ‘¢.. ... See Montreal Light, Heat & Power Consolidated v. M.N.R., [1942] S.C.R. 89; [1942] C.T.C. 1, affirmed by the Privy Council, [1944] A.C. 126; [1944] C.T.C. 94, and B.C. ... Clark, 19 T.C. 390 in these words: ‘ ‘ Circulating capital is capital which is turned over, and in the process of being turned over yields profit or loss. ...

Philip Vineburg, Q.C., respondent’s counsel, to ‘ other family companies or trusts composed entirely of members closely or remotely related to the Bronfman clan.” ... Before delving into a examination of this none too clear provision of the law, I should say that I am quite indifferently impressed with the lame excuse, legally speaking, that Allan Bronfman would have ‘‘.. exercised a very passive role in relationship to the company. ... In the present instance, the money that has been transferred belonged to the company and it is through the concurrence and the direction of the appellant, who was and still is a director of the company that such transfers of money were made by the company to the different donees. ’ ’ Before extending its corporate generosity to relatives of its five directors, the company had duly paid the full tax on its yearly income, so that the gifts and gratuities came out of its residual capital, all taxes acquitted. ...

Nor was the ‘‘ Partial Agreement As To Facts’’ referred to in the reasons of the Board offered in evidence by either party at the trial of the appeal to this Court. ... Nevertheless the evidence satisfies me that the ‘ ‘ family reasons ’ ’ were as much a feature of the transaction as was the conveyance of the property and were also as much if not more of an inducement to J. ... Nor was the appellant’s case advanced by Aubrey Macdonald’s choice of words when he said it was a ‘ business” transaction and that he and his father and brother had discussed the property and had arrived at a figure which, for the reasons he gave, they thought was a fair price” for the land to them. ...

Lord Simonds, with whom Lord Oaksey concurred, said at p. 32: ‘ The first point arises on the subscription by Lord St. ... N.E. $ 4,200.00 Automobile, Buick, bought in 1939 2,025.00 Property 520- 1st Avenue W. 4,800.00 Stocks and Bonds: 10 shares Canadian Utilities $ 1,000.00 15 “ Northwest Utilities 1,500.00 140 “ Calgary Power Co. 14,840.00 500 ‘** Chesterville 1,000.00 Dominion of Canada Bonds 12,000.00 $0,340.00. ... Taven- der said: ‘ They could have come from anywhere. ’ ’ As I recall his evidence, Mr. ...

Two sales he ignored, namely, the sale of this same Winterburn farm in 1960 to Star Land & Exploration Ltd., for $147,761 and in 1966 from Star Land & Exploration Ltd., to Scurry Rainbow Oil Ltd., for the same price. ... Ross does not explain the sale of the same Winterburn farm by Star Land & Exploration Ltd., to Scurry Rainbow Oil Ltd., in 1966 for the same price of $147,761, but he does admit — part of which is recited above — that Mr. ... Morris Roe and his connection with Star Land & Exploration Ltd., M.C.L. ...

The directors and agents of New Chamberlain re ceived 20,000 shares @ $1.15. ... O’Connor, Barrister & Solicitor, 320 Bay Street, Toronto 1, Ontario. ... Nicholson & Co. Ltd. and confirmations will be forwarded to you “In Trust”. ...