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Speaking of the position of the trustees, he said, [1933] S.C.R. at 293: ‘ ‘ Les ‘trustees’ n’en seront cependant pas propriétaires, dans le sens absolu du mot. ... & Bro. 648, H.L. It had previously been described as “a rule of common sense as strong as can be’’, by Lord Ellenborough, in Doe v. ... Leathern, [1901] A.C. 495 at 506: ‘*,.. a case is only an authority for what it actually decides. ...

Lord Thankerton, at p. 592, stated: “... the account to 30th June, 1921, cannot be reopened, as the amount of the liability there stated was correctly stated as the finally agreed amount of the liability and the subsequent release of the Respondents’ proceeds on the footing of the correctness of that statement.’’ ... Ford & Co., Ltd. v. The Commissioner of Inland Revenue (1926), 12 T.C. 997, where, in referring to the Woolcombers and Newcastle Breweries cases at p. 1004, he stated that these cases ‘‘went quite far enough to justify looking at the accounts and saying: ‘Nobody dreamt this was not a loss at the time, but it turns out it was not. ... In the British Mexican case Lord Thankerton said at page 592: “I am unable to see how the release from a liability, which liability has been finally dealt within the preceding account, can form a trading receipt in the account for the year in which it is granted. ’ ’ and Lord Macmillan said at page 593: “If, then, the accounts for the year to the 30th June, 1921, cannot now be gone back upon, still less in my opinion can the appellant company be required to enter as a credit item in its accounts for the eighteen months to 31st December, 1922, the sum of £945,232 being the extent to which the Huasteca Company agreed to release the appellant company’s debt to it. ...

., [1954] S.C.R. 737 at pp. 738, 739; [1954] C.T.C. 339 at 338, as follows: “The statement of Lord Clyde in Whimster & Co. v. ... It is a matter of substance, looking at the thing as it happened, as a man who knows nothing of scientific accountancy might look at it—it is the receipts against payments in trading. ’ ’ At p. 0992, Lord Thankerton says: “I am unable to see how the release from a liability, which liability has been finally dealt with in the preceding account, can form a trading receipt in the account for the year in which it is granted.” ... 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. ’ ’ The issue here is whether the admitted profit, realized by appellant in its financial year ending September 30, 1952, as a result of the special rebate arrangement with Nuffield, was a profit earned in the course of its trading operations as contended by the Crown, or a capital gain as contended by appellant. ...

Vancouver where the amounts paid for delivery have been less than the cost of delivery at Vancouver, by an equitable difference (according to market prices obtained for sour cream, sweet cream, and whole milk Provided always that from and out of the moneys realized from the sale of milk and/or cream during the term of this agreement the Association may deduct and retain from month to month such amounts for the purposes of the Association as its Directors may from time to time decide, which amounts shall not exceed in all 10 per cent. of the amount realized from the sale of the said milk and/or cream, and said amounts so deducted and retained by the Association together with similar amounts deducted and retained by. the Association from all other Producers delivering to the Association shall be a fund in the hands of the Association to be expended as follows:— " 4 (a) To provide for all losses, costs, charges and expenses incurred by the Association in carrying on its business together with a reasonable allowance for depreciation of all plants and equipment. ... These moneys deducted and retained by the Association " ‘for the purposes of the Association’’ are to be expended:—_ (1) In providing for all losses, costs, charges and expenses of the business of the Association, including an allowance for depreciation of plant and equipment, (2) in establishing a reserve fund in compliance with the statute, (3) in payment of a ‘‘cash dividend’’ to the shareholders of the Association, at such rate as shall be ‘‘fixed by the said Association, not exceeding eight per cent. per annum, ‘ ‘ (4) as to any surplus, after providing for these requirements, in paying a sum, not to exceed 21% per cent. of the total moneys realized, in the purchase of lands, buildings, machinery or equipment, or ‘‘ in making any other investment/’ deemed to be "‘for the benefit of the Association”; and in disposing of any balance of the surplus in such manner as the Association may determine in annual general meeting. ... Admittedly, by the contract, the moneys realized from the sale of milk and cream, were to be distributed " 4 about the middle and the end of each month,’’ or at such periods as might be fixed by the Association, subject to the monthly deduction above mentioned, which is not to exceed ten per cent. of the total amount realized from sales. ...

Subsection (1) of s. 9 is as follows: ^9(1) Subject to the exemptions provided for in sections 4 and 8,— " " (a)every corporation not liable to business assessment under section 8 shall be assessed in respect of income; "‘(b) every corporation although liable to business assessment under section 8 shall also be assessed in respect of any income not derived from the business in respect of which it is assessable under that section? ‘ The part of the income now in question arises entirely from dividends or interest received by the appellant from five other incorporated companies which, speaking generally, it controls. ... " '10. Subject to subsection 6 of section 39 the income of a partnership, or of an incorporated company, if assessable, shall be assessed against the partners at their chief place of business, and against the company at its head office, or if the company has no head office in Ontario, at its chief place of business in the municipality. ’ ’ The issue raised is, therefore, this: does the business of the appellant on Sterling Rd., Toronto, within the meaning of the Assessment Act, extend to that of the bauxite company or any of the other subsidiaries mentioned? ...

[Per Curiam]: — We are not satisfied that the payments by way of strike pay in this case come within the definition of "income... from a source" Within the meaning of section 3 of the Income Tax Act. ...

Her Majesty the Queen, [1993] 1 CTC 226, 93 DTC 5158 lacobucci, |.:— We are all of the view that this appeal should be dismissed for the reasons given by Mr. ...

Income tax — Federal — Income Tax Act, RSC 1952, c 148 — 12(1)(a), (h) — As an anaesthetist, the taxpayer was self-employed but, with a group of other anaesthetists, was attached to the Royal Jubilee Hospital in Victoria, where all of his professional services were rendered. ...

Solicitors for the defendant, appellant: Geoffrion & Prud’homme, Montreal. ...   [1] [1960] S.C.R. 619, 24 D.L.R. (2d) 1, 35 W.W.R. 241. [2] [1967] Que. ...

June 9, 1944 106 $ 4,500.00 Mun. of John LePage Assiniboia II. Dec. 14, 1944 154 $ 2,988.20 North John LePage Kildonan III. May 9, 1945 149.7 $ 6,680.00 Assiniboia Minnie LePage IV. Nov. 19, 1950 403 $12,896.00 North John LePage Kildonan V. ... LePage by having the lands farmed under crop leases.-... ‘ In March of 1956 the company decided to sell sufficient land to pay off the debentures and promissory notes. ...