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Corporation with the following explanation: To record portion of demand loan receivable from World T & I and demand loan payable to Cans Investment resulting from the loan by Caus to Cdn Schenley of $3,485,000 U.S. Funds which in turn was loaned by Cdn Schenley to World T & I Corp. ... Loan from Caus bears 6% interest, loan to World T & I is noninterest bearing. ...

Thereby, Imperial covenanted in consideration of the agreement (Exhibit 2) to supply monthly to each shareholder a complete statement of all prescriptions such shareholders had ‘ ‘ directed to us through the Prescription Optical Co. ... Ltd. for the price of $ on the following terms and subject to following conditions. 10% of the total amount each year. ... Galbraith’s allotment, he said: ‘ Dr. Galbraith was paid for the purchase of a share, for the sale of a share which represented his goodwill, the public’s goodwill and the patients’ goodwill. ...

Chipman, by Clause ‘‘Thirdly’’ she gave the whole of her estate to her executors and trustees on trust: “ ‘ (a) To pay all my just debts, funeral and testamentary expenses aS soon as possible after my death and to pay all succession duties, inheritance taxes, court fees and similar taxation on my Estate out of the capital of the residue of my Estate without charging same to my respective legatees and without the intervention of any of my legatees.’ ... I direct, moreover, that the bequests herein made while in the hands of my Executors and Trustees shall not be capable of being assigned by the beneficiaries.’ ” Following the death of his wife, the testator received the net interest and revenues from the residue of her estate as provided for in the opening words of Clause 3(f) of her will; and under the remaining provisions of the said clause, he demanded and received payment of $33,164.41 out of the capital of the residue of her estate. ... See, for example, Halsbury, 2nd ed., vol. 25 at p. 211: ‘A general power is such as the donee can exercise in favour of such person or persons as he pleases, including himself or his executors or administrators.’ ” Had I to reach a conclusion on this point, it would be necessary to give careful consideration to the terms of the will. ...

Chipman, by Clause ‘‘Thirdly’’ she gave the whole of her estate to her executors and trustees on trust: “ ‘ (a) To pay all my just debts, funeral and testamentary expenses aS soon as possible after my death and to pay all succession duties, inheritance taxes, court fees and similar taxation on my Estate out of the capital of the residue of my Estate without charging same to my respective legatees and without the intervention of any of my legatees.’ ... I direct, moreover, that the bequests herein made while in the hands of my Executors and Trustees shall not be capable of being assigned by the beneficiaries.’ ” Following the death of his wife, the testator received the net interest and revenues from the residue of her estate as provided for in the opening words of Clause 3(f) of her will; and under the remaining provisions of the said clause, he demanded and received payment of $33,164.41 out of the capital of the residue of her estate. ... See, for example, Halsbury, 2nd ed., vol. 25 at p. 211: ‘A general power is such as the donee can exercise in favour of such person or persons as he pleases, including himself or his executors or administrators.’ ” Had I to reach a conclusion on this point, it would be necessary to give careful consideration to the terms of the will. ...

These included the appellant’s income tax return, the notice of appeal, the Minister’s decision, the notice of dissatisfaction, the Minister’s reply thereto and also the notice of "‘as- sessment appealed” and all other documents and papers relating to " the assessment under appeal’’. ... Then section 66 gave this Court exclusive jurisdiction to hear and determine " all questions that may arise in connection with the assessment”. ... But, while the appeal to this Court was from the assessment and the issue before it was whether the assessment was correct, it was also provided by section 63(2) that after the filing of the documents referred to in section 63(1) the matter should " " thereupon be deemed to be an action in the said Court ready for trial or hearing’’. ...

To the same effect is the statement of Lord Sands in Whimster & Co. v. ... Indeed, the second reason of the Respondent’s case is that debts due to the Appellant from the purchasers of houses ‘were debts within the meaning of Rule 3(i) ’. ... William Dickinson & Co., Ltd., p. 162 ante). All the other matters, the deduction of which is disallowed, are expenditures, liabilities and disbursements. ...

The subsection then in force (1960-61, c. 17, Section 2(1) enacting Section 11(1) (qb)) reads as follows: (qb) where a taxpayer was during the year a student in full-time attendance at a university in a course leading to a degree, or in full-time attendance at a college or other educational institution in Canada in a course at a post-secondary school level, the amount of any fees for his tuition paid to the university, college or other educational institution in respect of a period not exceeding 12 months commencing in the year and not included in the calculation of a deduction under this paragraph for a previous year (except any such fees paid in respect of a course of less than 13 consecutive weeks’ duration); The appellant contends: (1) That ‘‘a taxpayer’’, the second and third words, should be read as “a person” or ‘‘any person’’ because the definition of a taxpayer reads: “ taxpayer’ includes any person whether or not liable to pay tax;” (Section 139 (1) (av)) and (2) That “by him’’ is implied after the word “paid” as meaning that the sum to be deducted must be paid by the father, the taxpayer. ... Therefore the appellant contends that as such other words are not to be found in paragraph (qb) ‘‘a taxpayer’’ should be read as ‘‘any person’’, and in the result the section should be construed to mean that where ‘‘ any person was during the year a student.... the amount of any fees for his tuition paid by him (the taxpayer, here the father)... ” That contention fails for various reasons. ‘‘ A taxpayer” is not defined simpliciter as ‘‘a person’’, and the definition merely means that a ‘‘person’’ to be a taxpayer need not be a payer but that definition does not excuse such ‘‘person’’ from having the other incidents of a taxpayer, which in this instance would. include the considering of what “may be deducted in computing the income of a taxpayer’’, the preliminary words of Section 11(1). ... Section 11(1) (q) (enacted 1956, c. 39, Section 3(5)) provided, where a taxpayer is a member of the clergy...’’; Section 11(1) (qa) (enacted 1956-57, c. 29, Section 4 (3)) provided ‘where a taxpayer is a teacher...’’; Section 11(1) (qb), the section in question (enacted 1960-61, c. 17, Section 2(1)) provided, “where a taxpayer was during the year a student... ”’ These subsections are evidently intended to authorized specific deductions to specific groups; by Section 11(1) (q) to clergymen for their residence, by Section 11(1) (qa) to teachers for certain contributions, and by Section 11(1) (qb) to students for certain tuition. ...

Frankel agrees to sell, transfer and convey to Federated … the following assets of its non-ferrous metals business, namely: (a) Machinery and equipment.... ... All ‘ raw materials, such as scrap metals, drosses, skimmings bo and residues, and all new or finished metals on hand at the time of closing hereunder. ... In Whimster & Co. v. C.I.R. (1925), 12 T.C. 813, Lord Clyde, in a passage which was cited with approval by the Privy Council in M.N.R. v. ...

For that reason the option from Millar & Coe was dropped. In the 1960’s, P. Burns & Co. Ltd. advertised the property in question, known as 715 Fisgard Street, for $62,000. ... In the decade commencing 1950 Mallek, for Eddy’s Limited, attempted to purchase the leasehold property of Millar & Coe next adjoining to the south and obtained a written option to purchase their business and an assignment of their lease, but Montague refused to allow the adjoining wall between Eddy’s Limited and the property of Millar & Coe to be opened so as to include the Millar & Coe building into the shop of Eddy’s Limited. ...

Neither should the cost of new buildings, if any are built, be increased by costs which bear no relation to the additions. ’ ’ And in Principles of Accounting—Intermediate, by Finney, Third Edition, it is stated at p. 308: “Buildings. ...