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In the taxation year 1963 the appellant’s wife sustained a loss on the farming operation of $1,322.88, made up as follows: Receipts Sale of farm products $ 782.73 Rent received 200.00 TOTAL $1,282.73 Expenses (incurred and paid by Mrs. ... This appeal is therefore dismissed with costs. * (September 7, 1966, Unreported.) 1 * “21. (1) Where a person has, on or after August 1, 1917, trans ferred property, either directly or indirectly, by means of a trust or by any other means whatsoever, to his spouse, or to a person who has since become his spouse, the income for a taxation year from the property or from property substituted therefor shall, during the lifetime of the transferor while he is resident in Canada and the transferee is his spouse, be deemed to be income of the transferor and not of the transferee.” "!' See Section 4 of the Act, which reads: “Subject to the other provisions of this Part, income for a taxa tion year from a business or property is the profit therefrom for the year.” 3 1- “12. (1) In computing income, no deduction shall be made in respect of (a) General limitation. ...

It has been said that ‘‘ What is plain to one mind may be just the reverse to another.’’ ... & El. 460, 468], and there are particular purposes for which express language is absolutely indispensable. ... If it were necessary or desirable to do so, I think it would be permissible to insert in Section 11(1) (£) “or amounts’’ after the word ‘‘amount’’, in virtue of the Interpretation Act, R.S.C. 1927. ce. 1, Section 31 (j), which states: “In every Act, unless the contrary intention appears, (j) words in the singular include the plural, and words in the plural include the singular. ’ ’ This is particularly true when one considers that the employer in this case is making payments or contributions to two plans which were underwritten by separate underwriters. ...

I shall hereinafter sometimes refer to the five above mentioned parties as the Rothenberg group ’ ’. ... He said that he had audited their books for many years and that he believed that one or more of them were owners of a corporation engaged in the real estate business known as Frank Cobrin & Sons. ... Luc Road, on JANUARY 20th, 1955 Minutes Book No. 9 — PAGE 208 COBRINS LIMITED RE DEVELPOMENT OF CADASTRE 93 Mayor Paris submitted letter of date January 17th from Messrs. ...

”’ It has been readily conceded by counsel for both parties that all essential elements to render the defendant liable are present, assuming the constitutional validity of subsections (9) and (10) of Section 50 of the Excise Tax Act. ... & C.N.R., [1958] S.C.R. 285 and Tennant v. Union Bank, [1894] A.C, 31. ... There is no question that the matter ’ ’ of raising money by any mode or system of taxation comes within a class of subjects declared by Section 91 of the British North America Act to be within the exclusive legislative authority of the Parliament of Canada. ...

The agreement of September 12, 1935, is between Wrights’ Ropes Limited, Birmingham, (called Wrights’); Charles Hirst & Sons Limited, (called Hirst’s) and the appellant (called the Canadian Company). ... Reid, [1911] A.C. at 182, where he Says: "‘They can obtain information in any way they think best— always giving a fair opportunity to those who are parties to the controversy for correcting or contradicting any relevant statements prejudicial to their view. ‘ ’ This decision was referred to with approval by Davis J. in the case of The King v. ... Following the tests laid down by the Privy Council in Pioneer Laundry & Dry Cleaners Limited v. ...

Bankes (1863) Vol. 3, De Gex, Jones & Smith’s Reports, 306. Under the English Act it has been held that an obligation by a husband in a marriage contract to make certain payments to his marriage contract trustees for the benefit of his wife and children, as the counterpart of similar obligations by his wife, could not be regarded on his death as a debt incurred by him for full consideration in money or money’s worth wholly for the deceased’s own use and benefit. ... I should say that it could not, therefore, cover any stipulation in a marriage contract, although reciprocal in character and issuing in a debt incumbrance, where the true consideration is a thing incapable of being expressed in money or money’s worth—to wit, the marriage itself. ’ ’ I am of the opinion, therefore, that if the obligation of the estate of Dr. ... Moreover, the inclusion in see. 3(1) (j) of "‘property agreed to be transferred to or settled on’’ (following as they do ‘‘ property transferred to or settled on’’) indicate that it refers to agreements not completed by transfer or settlement of the property itself and which property, therefore, remains in the possession of the ‘‘donor’’ at the time of his death. ...

Income Tax levied $507,796.13 Interest thereon levied-. 4,296.71 $ 512,092.84 3. ... Section 12, relating to assessment, is thus worded: " " 12. ... ‘ The record has never been completed in spite of numerous requests to counsel by the registrar. ...

I think so. ’ ’ Then he was asked (at p. 44 of the transcript): ‘‘Q. Well, supposing you hadn’t got the right to use the name, what was the alternative? ... Muller, [1901] A.C. 217 at pp. 223-224: “... It is the benefit and advantage of the good name, reputation, and connection to a business. ... M.N.R., [1965] C.T.C. 320, and which was referred to in John Smith & Son v. ...

Minogue & Co., Limited and Packsack Diamond Drill, Limited. Both these companies carry on business in North Bay, Ontario as manufacturers and distributors of diamond drill tools and equipment. ... Minogue & Co., Limited, made a small contribution to the capital of the company SO formed by the purchase of shares of its capital stock as did Mr. ... Both Marun and Minogue had been supplied with copies of the Excise Tax Act by the Department, receipt of which » was personally acknowledged by each of them. ...

Power has treated as capital, as was done in Sutton Lumber & Trading Company Ltd, v. ... Caulk Co. of Canada Ltd., [1954] S.C.R. 55; [1954] C.T.C. 28, by Rand, J. at pp. 57 and 31 as follows: ' ' The judgment of this Court in M.N.R. v. ... A-65), stated in part: " Their principal concern has been to obtain fair compensation for the common shares in the B.C. ...