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Paragraphs 18 and 19 of the Statement of Claim in this appeal are: ‘ ‘ 18. ... Smart recouped himself, and repaid Smart & Biggar, at first by depositing in Smart & Biggar’s account the whole of any profits from the Ottawa office of Fetherstonhaugh & Co., and paying no part to F. ... Not all money in the bank account of a partnership is " " income of the partnership’’. ...

Prior to the date of his death Wilson was the principal shareholder in Wilson Mining & Investment Company Ltd. ... Sec. 21 comprises several provisions in respect of ‘‘personal corporations’’ and subs. 1, 2 and 3 are as follows: " " 21. ... These expenses were disallowed on the ground that they were "" disbursements or expenses not wholly, exclusively and necessarily laid out or expended for the purpose of earning the income,’’ as provided by s. 6(a) of the Act, and which are not allowable " ‘ in computing the amount of the profits or gains to be assessed. ‘ ‘ The revenue of the Wilson Company came almost entirely from two sources, the Bond Investments and Premier Gold Mining Company. ...

Ltd. “... including, reads article II, the profits which may be realized by the joint venture...” ... Ltd. and Fred Mannix & Company ‘‘... for the better procurement of the monies required for the performance of the said work... under the Mannix interest in the prime agreements,’’ i.e., those of November 12 and 23, same year. ... Early in September, 1950, appellant sold its interest to Fred Mannix & Co. ...

In 1928, Oka Sand & Gravel Co. Ltd. merged with a company called ‘‘Consolidated Sand’’ and these two companies were absorbed by a new company called ‘‘Consolidated Oka Sand & Gravel Co. ... A-5 and A-6) between Consolidated Oka Sand & Gravel Ltd. as vendor to Oka Sand & Gravel Co. ... As appears at page 2 of the re-assessment referred to in his notice of appeal, the $40,000 in issue was added as ‘ ‘ profit on the sale of sand’’ included in the slump sale in question. ...

Lily Wurtele, ‘‘... during the lifetime of the parties and so long as the plaintiff shall live separate and apart from the Defendant... ” (exhibit 1, para. 4), was delayed until September 16, 1932, when the Local Master of the Court, after stipulating a monthly payment of $600 to the wife, purported to draw up a settlement deal ‘‘... in connection with the existing insurance policies upon the life of the Defendant... ” (ef. exhibit 2, paras. 3 and 4.) ... Next, the Shorter Oxford Dictionary in turn defines “gift” as: ‘ ‘ A transfer of property in a thing voluntarily and without any valuable consideration. ” Black’s Law Dictionary, 4th ed., 1951, lends additional emphasis on the voluntary and gratuitous characteristics of a gift. ... The judgment of the Court was read by Evershed, M.R., who, inter alia, said that: ‘ ‘... ...

Another similar case is that of Charles Brown & Company v. C.I.R., 12 T.C. 1256. ... Then, after adopting what was said by Rowlatt, J., and Lord Hanworth, M.R., and Lord Macmillan in the British Mexican Petroleum case, the President said: ‘ ‘ It appears to us that this is an identical case. ... That being so, it cannot be found that the abatement of a capital indebtedness — as in the instant case — can give rise to taxable income. ...

In the forms attached to the assessments, it was stated: " " You are deemed to be in the business of lending money and purchasing mortgages at a profit, and under section 3(a) and section 4 of The Income Tax Act, to be taxable on the profits therefrom. ‘ ‘ It appears that the full amount of the tax levied by the assessments in dispute has been paid under protest. ... Mac- naghten, J., on appeal, held that it was not an operation within the meaning of " " trade” because there was no "‘dealing’’ in the policies in the sense of their being bought and sold again, since they were bought to keep and not to sell. ... These were the indicia of trade, or the manner in which Barry " " organized himself in a commercial and mercantile way ’ ’ which resulted in the finding that he was engaged in a concern in the nature of trade. ...

Excluding those made in 1945 and 1946, the annual sales from Plan 191 were as follows: 1947 — 14 1951 — 2 1948— 8 1952 — 3 1949— 3 1953 — 4 1950— 8 À small number of sales were also made in 1954, 1955 and 1956. ... For the years 1947 and 1948 the matter is to be determined under the provisions of the Income War Taz Act, which was as follows: " " 3. For the purposes of this Act, ‘ income ‘ means the annual net profit or gain or gratuity whether ascertained and capable of computation as being wages, salary, or other fixed amount or unascertained as being fees or emoluments, or as being profits from a trade or commercial or financial or other business or calling directly or indirectly received by a person... or from any trade, manufacture or business...; and shall include... and also the annual profit or gain from any other source including”? ...

It held a large number of shares of the capital stock of James Richardson & Sons Ld., a grain company in which Mr. ... Richardson’s principal business was the grain company of James Richardson & Sons Ld. He had transferred to Interprovincial the stock which he owned in James Richardson & Sons Ld. and he had suggested to his relatives that they also transfer to Interprovincial their holdings in James Richardson & Sons Ld. ...

& D. Holdings Inc. the said land having an area of 4,500,966 square feet. 5. ... & D. Holdings Inc. were owned by Caracas Investment Corporation. 10. ... & D. Holdings Inc. and Advance Holdings Ine. On March 7, 1949 D. & D. ...