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Minister of National Revenue, [1957] CTC 146, 57 DTC 1098 / THORSON, P. ... The appellant is the president and principal shareholder of Alliance Advertising & Applied Arts, Inc., a Quebec corporation. ... It is the one thing which distinguishes an old established business from a new business at its first start. ‘ ‘ That the goodwill of a business is an item of property that can be the subject of sale is beyond dispute: vide Wedderburn v. ...

Dunwoody & Company. In the taxation year 1962 this partnership bought the accounting practice of Morphy, Boyter & Adams of Trenton, Ontario for the sum of $20,000, and the bookkeeping practice of Lola and Frank Corcoran of Long Sault, Ontario for the sum of $5,101. ... I Goodwill $ 1.00 II List of all present and past clients of the Book keeping Practice, historical records, working papers, ledger cards, files and other records per taining to the services provided as set out on Schedule “A” to this Agreement $ 5,100.00 $ 5,101.00 In my view, the issue may be determined by answering two questions, namely, firstly, what is purchased goodwill? ... Rea, C.P.A., managing partner of Rea & Associates, New Philadelphia, Ohio. ...

Reported income (net) Taxed income 1949 $ 4,596.88 $12,000.00 1950 2,930.04 12,000.00 1951 3,060.34 19,000.00 1952 3,076.66 19,067.21 1953 3,446.35 29,206.21 $17,110.27 $91,273.42 Such a gap between a reported net income, for the five-year period, of $17,110.27 and a corrected one of $91,273.42, was certainly not bridged by the appellant whose evidence might be fairly, albeit concisely, summarized thus: ‘ ‘ I may have erred in certain items of my income tax reports. ... Rentals duly receipted Repairs claimed 1949 $ 4,412.60 $ 2,055.50 1950 12,433.50 6,081.75 1951 15,148.00 9,607.00 1952 19,793.35 12,306.33 1953. 27,055.50 16,405.01 $79,842.95 $46,455.59 Needless to say very little doubt can be entertained on the score of rentals acknowledged by corresponding receipts, but skepticism, akin to disbelief, attaches to the would-be off-setting total of more than half the gross rentals. In an ordinary ease, such a poor investment would be improbable, the ‘‘ peculiarities’’ of this one render it untenable. ...

That is where several words are followed, as here, by a general expression (such as ‘‘or other body and any corporate body >,>), that expression is not limited to the last particular unit of the group, but applies to them all. ... At p. 109 of the Exchequer Court Reports (1925) the trial judge prefaces his decision by stating: ‘ " Every person ordinarily resident in Canada is liable to income tax.’’ ... Words, which are equally consistent with the absence of such an intention, are not sufficient. ‘ ‘ All of this is quite apposite to the present case. ...

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, subsection (1) (av) of the Act is as follows: i ‘127(1) (av) a taxpayer’s income from a business, employment, property or other source of income or from sources in a particular place means the taxpayer’s income computed in accordance with this Act on the assumption that he had during the taxation year no income except from that source or those sources of income and was entitled to no deductions except those related to that source or those sources;’’ The Shorter Oxford English Dictionary gives the following meanings of the word ‘ source ’ viz.: “1. ... The following is found in volume 58, Corpus Juris, page 811: ‘ Source. ... C.L.R. 183 at 189, Isaaes, J., said: “The legislature in using the word ‘source’ meant, not a legal concept, but something which a practical man would regard as a real source of income. ’ ’ The word ‘‘source’’ as used in the Act is a correlative term and there can no more be, at its inception, income without a source of income than there can be a child without a mother, and the converse. ...

In the case In re South African Supply and Cold Storage Company (1), Buckley J. had to consider whether or not there had been a winding-up "‘for the purpose of reconstruction or amalgamation, ‘ ‘ and he said ‘‘that neither the word reconstruction nor the word amalgamation has any definite legal meaning. ... That reserve there appears as a liability ‘‘To the Shareholders, ‘ ‘ in the sum of $335,000. ... This section would be applicable to s. 4 of the Act of 1930, enacted as s. 19 (1) of the Income War Tax Act, and while those two sections would appear to be in conflict as to the period when the tax became exigible, yet, it would seem clear that they are to be read as referring to ‘‘undistributed income ‘ ‘ earned in either the 1929 or the 1930 taxation period, and subsequent periods, and not to income earlier earned, and on hand and undistributed. ...

:—This appeal was heard in Vancouver and the evidence and argument submitted were identically the same as that submitted in the appeal of the Army & Navy Department Store Limited v. ... My decision in the appeal submitted to this Court by the Army & Navy Department Store Limited was filed on this date and a copy of said decision is attached hereto. ...

:—This appeal was heard in Vancouver and the evidence and argument submitted were identically the same as that submitted in the appeal of the Army & Navy Department Store Limited v. ... My decision in the appeal submitted to this Court by the Army & Navy Department Store Limited was filed on this date and a copy of said decision is attached hereto. ...

A notice of assessment under Section 12 of the Hstate Tax Act was prepared, is dated February 27, 1964 and was addressed and sent to ‘‘ Executors, Est. of Bernard E. ... SMITH the following arrears of Estate Tax INTEREST ASSESSMENT DATE TAX PENALTY INTEREST COMPUTED TO 27 Feb/64 $7,890.30 — $1,517.52 15 Sept/65 Constituting a total amount of $9,407.82 together with additional interest at the rate of 5% per annum on the sum of $7,890.30 from 16th day of. ... This writ of extent was served upon the Toronto firm of Peat, Marwick, Mitchell & Co., Certified Public Accountants, Prudential Building, King and Yonge Streets, Toronto 1, Ontario which the applicant by affidavit alleges is associated with the New York firm of Peat, Marwick, Mitchell & Co. of which the applicant is a partner but which is a separate and distinct firm from the Toronto firm. ...

In the taxation year 1963 the appellant’s wife sustained a loss on the farming operation of $1,322.88, made up as follows: Receipts Sale of farm products $ 782.73 Rent received 200.00 TOTAL $1,282.73 Expenses (incurred and paid by Mrs. ... This appeal is therefore dismissed with costs. * (September 7, 1966, Unreported.) 1 * “21. (1) Where a person has, on or after August 1, 1917, trans ferred property, either directly or indirectly, by means of a trust or by any other means whatsoever, to his spouse, or to a person who has since become his spouse, the income for a taxation year from the property or from property substituted therefor shall, during the lifetime of the transferor while he is resident in Canada and the transferee is his spouse, be deemed to be income of the transferor and not of the transferee.” "!' See Section 4 of the Act, which reads: “Subject to the other provisions of this Part, income for a taxa tion year from a business or property is the profit therefrom for the year.” 3 1- “12. (1) In computing income, no deduction shall be made in respect of (a) General limitation. ...