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The term “demonstrator” arose, I think, because of the fact—as will appear later—that the nine cars were carried for a time in Account 242 ‘ ‘ Inventory demonstrators ’ ’. ... Mr McConnan explained that the latter step was done at the request of General Motors, and, he added significantly, ‘‘to keep the unit count correct of the stock on hand ’ \ It will be seen, therefore, that the nine cars in question, from the time of their acquisition were carried in the accounts ‘ ‘ Inventory new cars and trucks’’, and ‘‘Inventory demonstrators’’, until the end of the year. ... Account 242 is also an inventory account called ‘* Inventory demonstrators’’. ...

Eallien Crawford-Brown (now deceased). 1929 • Income Tax Appeal. " " The appeal of the above named taxpayer against her assessment for 1929 on the ground that she was entitled to a life interest only in the estate of Sir Lyman Melvin Jones and accordingly that she should not be taxed on any portion of the premium received by the estate on the redemption of preferred shares of Massey-Harris Co. ... In addition to the said reasons, the appellant submits that the word " premium ’ has many meanings.” The notice then cites definitions of the words "premium'' and "" bonus” from Murray’s New English Dictionary and it continues as follows: " " The appellants submit that a fair and usual interpretation to be placed on the word ‘premium’ is that it is a bonus, i.e., an extra dividend. ...

In 1959 — The production stage of mining progressed. — The development stage of mining also progressed. — Construction of the smelter buildings was completed. — Construction of the refinery was commenced. — Further construction of the townsite progressed. In 1960 — The production stage of mining progressed. — Both the mill and the smelter were in operation. — The refinery construction progressed. — The construction of the Townsite further progressed. In 1961 — The production stage of mining continued. — Development commenced in a new area of the mine. — The refinery commenced operation. — The construction of the Townsite further progressed. ...

Section 58 of the Act, prior to its amendment in 1944, read as follows: " " 58. ... Then section 66 provides: " *66. Subject to the provisions of this Act, the Exchequer Court shall have exclusive jurisdiction to hear and determine all questions that may arise in connection with any assessment made under this Act etc. ’ ’ This language is, I think, clearly wide enough to cover questions affecting the validity or correctness of the assessment and any complaint the appellant may allege or have against it. ... The use of the word ‘ ‘ allow ‘ ‘ in the section connotes that there is a claim before the Minister for his consideration. ...

The Respondent in computing his income, deducted from his total income the following amounts: Member’s contribution to Legislative Assembly Retirement Allowance account $ 561.00 Registered retirement savings plan premiums 939.00 $1,500.00 and estimated his federal tax payable for 1965 to be $7,197.59 and his provincial tax payable for 1965 to be $1,961.13. 7. ... The Board’s judgment does not appear to refer to Section 139(1) (av) of the Income Tax Act, which says that, where the word " taxpayer” is used in that Act, it includes "‘any person whether or not liable to pay tax’’. In my view, there is no question that Her Majesty is a " " person ’ ’ and that the references in this appeal to the Province of Ontario are references to Her Majesty. ...

Nor do I think the present problem is to be solved by endeavouring to determine the ‘ ‘ source ’ ’ of the income to the particular taxpayer. ... Ingram’s work on South African Income Tax Law by de Villiers J. in his dissenting judgment: Source means not a legal concept, but something which a practical man would regard as a real source of income’; ‘the ascertaining of the actual source is a practical hard matter of fact.’ ” In Hart v. ... He said at page 788: * Their Lordships have no criticism to make of any of those decisions, but they desire to point out that decisions on the words of one statute are seldom of value in deciding on different words in another statute and that different business operations may give rise to different taxing results.” ...

In 1959 Johnson Walton Companies merged with Reid, Shaw & McNaught, insurance brokers, and the appellant has since continued as a partner of that firm. ... Estates, was to finance each of other companies called * ‘ little companies ’ ’ to build an apartment block or commercial building in Vancouver, and the business was carried out as follows: Whitelaw would select a property suitable for building and if approved by the directors of Welfar, a little company would be formed to purchase the property and to build thereon an apartment block or commercial building. ... M.N.R., 25 Tax A.B.C. 234; Osler, Hammon & Nanton Ltd. v. M.N.R., [1961] C.T.C. 462; [1963] C.T.C. 164. ...

Date Name Cent Mortgage Bonus Refund Off 3 1/ 3/55 Kosowan 7 $ 6,000 $ 350 nil 23/6/55 4 1/ 9/55 Zimmel 6 $ 9,000 $ 1,200 $600 30/1/56 5 15/10/56 Fort Hotel 7 $ 33,000 $ 3,300 nil 15/5/59 6 1/ 8/57 Moss Holdings 7 $200,000 $25,000 nil in existence 7 13/ 1/55 Hawkeye 7 $ 1,650 nil 28/2/57 8 15/10/56 Hamilton 7 $ 40,000 $ 5,000' nil in existence 9 1/ 4/55 Thorpe 7 §$ 15,500 $ 8,100 nil The only witness heard, and he was so heard on behalf of the appellant, was the president and general manager of the appellant company (hereinafter sometimes referred to as ‘‘the taxpayer”), Mr. ... That is right. ’ ’ The appellant company operates in the provinces of Saskatchewan, Alberta, British Columbia and the Northwest Territories, where they have salesmen. ... The third head of the Memorandum professes to state the objects of the Company, and in head (6) of this enumeration occur the words ‘to vary the investments of the Company, and generally ‘ ‘ to sell, exchange, or otherwise dispose of, deal with, or turn to account any of the assets of the Company’’.’ ...

In its income tax return for that year the appellant claimed, under the head of " " Sundries ’ ’, that it was entitled, in computing its taxable income to deduct as an expense the sum of $9,527.29 which it had paid to various social clubs in payment of the admission fees and annual membership dues of certain officers who were members of such clubs. ... Lion Brewery Company Limited (1910), 5 T.C. 568 at 581: " " It is clear that it is not every expenditure which is made by a trader for the promotion of his trade, and which, in fact, contributes to the earning of profits, which is a permissible deduction from the estimate of profits for Income Tax pur- poses? ... M.N.R., [1944] A.C. 126 at 133, where he said: " " Expenditure to be deductible, must be directly related to the earning of income.” ...

The accounting for sales of topsoil was left to the owner of Circle ‘ ‘ J ’ ’ Ranches Ltd. and difficulties were experienced in obtaining satisfactory accounts and credits. ... Add: 25% corner influence $ 27,273. $ 516.354. ($36.00 sf) on 40’ (2) 179'4" x 80’ = 14,350 sf at $2,180. ff or $27.27 sf $391,264. Add: 25% corner influence $ 21,818. $ 413,082. ($28.80 sf) on 40' (3) 76'6%" X 100’ = 7,656 sf at $1,820. ff or $18.18 sf $139,200. ...