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LESQUELS font les conventions suivantes: (A) — LA PARTIE DE PREMIÈRE part s’engage à emprunter la somme capitale de DEUX CENT SOIXANTE-QUINZE MILLE dollars ($275,000.00) par voie d’émission d’actions privilégiées aux taux et conditions ci-après spécifiées; (B) — Le but de cet emprunt est de consolider une dette d’environ soixante-cinq mille dollars ($65,000.00) et de parachever certaines constructions déjà commencées; (C) — Pour prélever ladite somme de $275,000.00, la partie D première PART s’oblige d’utiliser les services de la PARTIE de DEUXIÈME PART exclusivement aux conditions ci-après apposées; CES FAITS étant ÉTABLIS, les parties aux présentes les précisent de la façon suivante: Conditions DU PRET 1 — Montant: DEUX CENT SOIXANTE-QUINZE MIL dollars ($275,000.00); 2° — Durée: Dix ans (10) à compter du quinze juillet prochain mil neuf cent quarante-six; 3° — Taux: CINQ POUR CENT L’AN (5%) payable semi- annuellement les quinzièmes jours de janvier et de juillet de chaque année, le premier versement d’intérêt devenant dû le quinze juillet de l’an prochain et ensuite semi-annuellement comme susdit; l’intérêt sera payable au domicile du souscripteur de l’action; 4° — REMBOURSEMENT: VINGT-SEPT MILLE CINQ CENTS dollars ($27,500.00) au minimum annuellement par voie de tirage au sort à une période laissée au choix de LA PARTIE DE PREMIÈRE PART; Les remboursements sur le capital s’effectueront au bureau principal de LA PARTIE DE PREMIÈRE PART et il devra être donné aux détenteurs immatriculés de telles actions un avis de soixante jours les informant que une ou toutes leurs actions leur seront payées. ... The fact of certificate A-6 reads as follows: ‘ Certificate ACTIONS 2 ACTIONS No. ... Conformément aux dispositions du 2e paragraphe de l’article 5 de la loi des sociétés coopératives agricoles, les actions privilégiées ne confèrent pas à leurs détenteurs le droit d’assister et de voter aux assemblées générales. ’ ’ The only difference of substance between the front of Certificate A-6 and that of Certificate A-l is that in the latter the date of the resolution of the board of directors is given as July 8, 1943. ...

Therefore, there remains to be determined whether the rock bolt is a “ safety device and equipment for the prevention of accidents in the manufacturing or production of goods’’ (the italics are to indicate the questions left to be considered). ... The word “safety” together with the words ‘‘for (i. e. with the purpose of) the prevention of accidents in the manufacturing or production of goods ’ ’ imply that the purpose for which the device is designed and used is to prevent such accidents, while the purpose for which the rock bolt is designed and used is the retention of the contour. of the underground cavity and, therefore, the making possible. of mining which, of course, can only be possible if the formation of the cavity is retained and men can work safely therein. Therefore, I agree with the finding of the Tariff Board that these rock bolts were ‘ ‘ essentially structural devices d'T no safety devices”. ...

John’s Trust Syn- dicate in 1952 $ 77,285.05 Less cost of same @ $1.00 per share 37,500.00 $ 39,785.05 for 1954 proceeds from sale of shares of Inland Natural Gas Co. ... Ltd. $ 55,721.50 Less cost at $1.00 per share 21,000.00 $ 34,721.50 The appellant, who had been the owner of 27 out of 164½ units created under an agreement known as the St. ... John Oil & Gas Co. Ltd., Yankee Princess Oils, Ltd., Inland Natural Gas ‘- o. ...

C. c. 32—57 & 58 V. c. 33 (D)—58 & 59 V. c. 23 (D). By 57 & 58 Vict. ch. 33, sec. 4, duties are to be levied upon certain specified goods "when such goods are imported into Canada. ... —We must read the statute 58 & 59 Vict. ch. 23, under which, in connection with R. ... & B. 923. [5] 3 ed. p. 298. [6] 1 Gallison 353. [7] 9 Cranch 104. [8] 1 Peters C. ...

The trustees used the $300,000 to purchase 4,000 common shares of Hiram Walker, Gooderham & Worts Ltd. at $75 per share. The deceased died on May 8, 1946, and at this date the 4,000 common shares of Hiram Walker, Gooderham & Worts Ltd., still formed part of the trust property and had increased in value to the sum of $558,000. ... It is common ground that the execution of the trust agreement coupled with the transfer of the shares constituted a ‘ ‘ disposition” and that duty is payable with respect thereto. ...

Opposite this last entry but under column 6, which is headed "" Occupation ”, appear the words ‘‘mining rights’’. ... By that time the Revised Statutes of Ontario 1937 were in force wherein the Assessment Act appears as ¢, 272. ... (k), (m), (n) and (o) of s. 1 of the Mining Act, R.S.O. 1927, ce. 45 (now R.S.O. 1937, ¢. 47, s. 1, cis. ...

By the first paragraph thereof (entitled ^sales’’), the Firestone Co. grants to MacKenzie, White & Dunsmuir Ltd. ... But it was explained that the new arrangement was made because MacKenzie & Co. felt that they would save money on the premiums, in view of the fact that the Firestone Co. was able to make a Dominionwide contract and that, in such a way, the saving on the premiums would accrue to MacKenzie & Co. ... At p. 52, it was stated:—"‘The decisions do not seem to furnish authority for going further back, for the purpose of taxation, than the business from which profits are directly derived, and the contracts which form the essence of that business/ ‘ Referring to this statement and to a statement in Grainger & Son v. ...

The Company will make an annual contribution of a sum based upon the ratio of its profits to invested capital which will adjust the total monthly contributions made by the Company to the following schedule: ‘ Invested Capital’ shall mean the total of all Capital Stock and Surplus (or equivalent) accounts and Long Term Debt of the Company as of the beginning of the preceding calendar year, as reflected in its printed Annual Report to stockholders. ... Company Contribution Per Cent of Profits as per cent of to Invested Capital Member Contribution Up to but less than 11%-—— 50% 11% but less than 12%.......... 55% 12% but less than 13% 60% 13% but less than 14% —- 65% 14% but less than 15%, 10% 15% or over —.... 15% This annual contribution, if any, shall be made as of March 31 of each year, beginning in 1955, and shall be related only to total member contributions made in the preceding calendar year which have not been withdrawn as of said March 31.” Paragraph 4 of the Agreed Statement of Facts sets out the contributions made by the Company in respect of Canadian members of the plan since the inception of the plan in 1953 up to the end of 1959 as follows: “Year Contributions in respect of Canadian members only Section IV Section IV Part A Part B Monthly Annual 1953.1 $ 120 None 1954 388 None 1955 903 None 1956 1,738 84 1957 3,146 None 1958 4,175 None 1959 8,592 None $19,062 $ 84” Section 79(1) of the Income Tax Act reads: “79. (1) In this Act, an ‘employees profit sharing plan’ means an arrangement under which payments computed by reference to his profits from his business or by reference to his profits from his business and the profits, if any, from the business of a corporation with whom he does not deal at arm’s length are made by an employer to a trustee in trust for the benefit of officers or employees of the employer or of a corporation with whom the employer does not deal at arm’s length (whether or not payments are also made to the trustee by the officers or employees), and under which the trustee has, since the commencement of the plan or the end of 1949, whichever is the later, each year allocated either contingently or absolutely to individual officers or employees, (a) all amounts received by him‘from the employer or from a corporation with whom the employer does not deal at arm’s length, and (b) all profits from the trust property (computed without regard to any capital gain made by the trust or capital loss sustained by it at any time since the end of 1955), in such manner that the aggregate of all such amounts and such profits minus such portion thereof as has been paid to beneficiaries under the trust is allocated either contingently or absolutely to officers or employees who are beneficiaries thereunder. ’ ’ Other subsections of Section 79 provide, inter alia, that the amount of payments into the plan made by the employer and allocated by the trustee to an employee either contingently or absolutely during the year are required to be included in the employee’s income for the year. ...

VI, ce. 63, Section 4, subsection (5), read as follows: “ 4 Income’ as hereinafter defined shall for the purpose of this Act be subject to the following exemptions and deductions...: (w) Such amount as the Governor in Council may, by regulation, allow for amounts paid in respect of taxes imposed on the income, or any part thereof, by the Government of a province by way of tax on income derived from mining operations or income derived from logging operations. ’ ’ Subsection (6) of Section 4 of 11 Geo. VI, c. 63, reads as follows: “ (6) Paragraph (w) of subsection one of section five of the said Act, as enacted by subsection five of this section, is applicable to income of the nineteen hundred and forty-seven and subsequent taxation years and to tax payable thereon but in the case of the nineteen hundred and forty-seven taxation year no amount may be deducted thereunder greater than that proportion of the total amount that might be deducted in respect of the whole taxation year that the number of days in the said taxation year in the calendar year nineteen hundred and fortyseven is of the number of days in the whole of the taxation year. ’ ’ By Section 2(2) of 11 and 12 George VI c. 53, (assented to on June 30, 1948) paragraph (w) was repealed and the following was substituted therefor: “ (w) such amount as the Governor in Council may, by regulation, allow in respect of taxes on income for the year from mining or logging operations.’’ ... The deduction authorized is the amount ‘‘ in respect of taxes paid to... a province on income derived from logging operations.’’ ...

The Memorandum of Association and the Articles of Association adopted by each was identical and each was authorized to issue 50,000 Class ‘‘ A ” common shares and 50,000 Class “B” common shares without nominal or par value. ... Subject to the other provisions of this Part, income for a taxation year from a business or property is the profit therefrom for the year. ’ ’ Section 127 (1): ‘ In this Act, (e) “business’ includes a profession, calling, trade, manufacture or undertaking of any kind whatsoever and includes an adventure or concern in the nature of trade but does not include an office or employment;” The learned trial judge, after reviewing the evidence, said in part: “In my view, no distinction can be drawn between the five items of profit now under consideration. ... That presumption may, of course, be negatived by the evidence as was done in the ease of Sutton Lumber & Trading Company v. ...