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Finally, however, he abandons this, as shown in the following abstract from his evidence at p. 205: * * Exhibit 27. ... The learned Chairman of the Municipal Board in his reasons says: " " There was considerable evidence offered, both by the appellants and by the City of Toronto, setting out the way in which the assessment of this property had been originally made, and setting out the value of the property both for race track purposes, and as a subdivision in the City of Toronto in the event of the racing being abandoned and the property sold as a subdivision.” ... He argues that the respondent, carries on a business, and therefore comes within the language of subsec. 1(j) quoted above, although not expressly mentioned, because the ejusdem generis rule does not apply, by virtue of see. 9 (12) which reads as follows: “. ...

The appellant included in the respondent’s income the sum of $669,900, which sum was arrived at as follows: Sale of Bellamy Hill property to The Great-West Life Assurance Company   $  1,000,000 Cost of land (215 acres) exchanged for Bellamy Hill property $   272,600   Provision for loss on land under option with City of Edmonton, 217 acres at $265 $     57,500 $      330,100 Gain   $      669,900 The respondent appealed from this assessment. ... Ft. ## $1,000,000 It is obvious that the value thus arrived at was not the value of the site as delivered by the City. ... Solicitors for the respondent: Stikeman, Elliott, Tamaki, Mercier & Robb, Montreal.   ...

Section 132(1)(a) and (d) of the Income Tax Act, so far as material, reads as follows: (1) Every person who has (a) made, or participated in, assented to or acquiesced in the making of, false or deceptive statements in a return, certificate, statement or answer filed or made as required by or under this Act, or a regulation, * * * (d) wilfully, in any manner, evaded or attempted to evade, compliance with this Act or payment of taxes imposed by this Act,… is guilty of an offence and, in addition to any penalty otherwise provided, is liable on summary conviction [to a fine or to the fine and imprisonment]. ... Solicitors for the respondent: Mahony & Dawson, Calgary.   [1] [1970] C.T.C. 397, 70 D.T.C. 6247. [2] [1970] C.T.C. 397, 70 D.T.C. 6247. ...

If profit, it is a fortuitous profit. ’ ’ He likens these securities in the hands of the respondent to timberlands held by a logging company, and rejects the view that in contrast to that situation, here there is a case of dealing in securities and that they are bought for resale. ... To sustaint the interest of patrons, the proprietor may be obliged to keep the collection revolving and in that way keep buying and selling pictures even though he has no desire to be a dealer and though he is ‘‘as likely to lose as to gain by his dealings, ’ ’ and he adds: “Similarly the appellant keeps securities not as a dealer but as an inducement to persuade clients to buy and to pay it commissions. ... But it is equally well established that enhanced values obtained from realisation or conversion of securities may be so assessable, where what is done is not merely a realisation or change of investment, but an act done in what is truly the carrying on, or carrying out, of a business. ’ ’ The part of the foregoing statement material to this discussion was quoted with approval by Duff, J. ...

Pre March 31, 1977   Income tax source deductions $2,550.78 Canada Pension Plan, employee portion 275.43 Canada Pension Plan, employer portion 275.43 Unemployment Insurance deduction employee portion 244.77 Unemployment Insurance deduction employer portion 342.68 Interest and penalties 647.25         TOTAL ASSESSMENT $4,336.34     2. Post March 31, 1977   Income tax source deductions 2,068.05 Canada Pension Plan, employee portion 220.05 Canada Pension Plan, employer portion 220.05 Unemployment Insurance deduction employee portion 196.16 Unemployment Insurance deduction employer portion 274.63 Interest and penalties 495.89           $3,474.83 [Page 1189] The amounts under the heading “Pre March 31, 1977” were claimed in respect of wages paid by the company before the receiving order and as to this the trial judge made the following finding (at p. 660): … Because of the specific allegation of Mr.  ... Solicitors for the plaintiff, appellant: Aikins, MacAulay & Thorvaldson, Winnipeg. ...

., [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. ...

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? ...

In 1965 appellant, (“ Cablevision ”), bought the assets of a company called Dupont Television Corporation and three of its subsidiaries. ... Solicitors for the appellant: Stikeman, Elliot, Tamaki, Mercier & Robb, Montreal. ...   [1] [1975] C.A. 81. [2] (1897), 27 S.C.R. 406. [3] [1926] S.C.R. 515. [4] [1926] S.C.R. 655. [5] (1935), 60 Que. ...

Licence Number (Name of Purchaser) ” Before 1945 furnaces were subject to sales tax. ... (NOTE. — Except in respect of goods conditionally exempted according to use.) ... I would allow the appeal with costs, set aside the judgment of the Exchequer Court and dismiss the Crown’s Information with costs. ’’ ...

Le revenu d’un contribuable pour une année d’imposition, aux fins de la présente partie, est son revenu pour l’année de toutes provenances à l’intérieur ou à l’extérieur du Canada, et, sans restreindre la généralité de ce qui précède, comprend le revenu pour l’année provenant (a) d’entreprises, (b) de biens, (e) de charges et d’emplois. ’ ’ ‘ ‘ 4. ... Dans son jugement très élaboré il s’exprime de la façon suivante: ‘“Pour toutes ces raisons, je suis d’opinion que pendant la durée de la communauté, le mari est seul propriétaire des biens qui composent l’actif de la communauté et seul responsable des charges qui en constituent le passif. ’ ’ Il conclut qu’étant seul propriétaire des biens communs, le mari doit seul payer l’impôt. ... The learned President rightly held that the case was within the principle of Mersey Dock & Harbour Board v. ...