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Peacock — $110,000 To Isabel Manley — $110,000 To Donald George Ewen — $ 55,000 To Kenneth Ewen — $ 55,000 Total — $550,000 Purcell shall pay $150,000 on account of the said sum of $550,000 by April 15, 1956 as follows:— To Joseph Sedgwick — $ 60,000 To Kenneth W. Peacock — $ 30,000 To Isabel Manley — $ 30,000 To Donald George Ewen — $ 15,000 To Kenneth Ewen — $ 15,000 3. ... Under the 1949 agreement the lenders became partners in the firm of Jack Purcell & Company. 2. ...

With reference to the appellant’s appeal against the assessment of the profits which it made from the acquisition and dis- position of certain vacant lands, it appears that the appellant, which was incorporated in 1949, did acquire certain revenue producing properties which, for the purposes of this appeal it may be assumed, were acquired for the purpose of obtaining a rental revenue from them and, in addition, in 1953, it started acquiring farm properties near the Côte-de-Liesse Road on Montreal Island, some of which properties were disposed of by it in a manner that is sufficiently indicated by a statement entitled ° Reconciliation of Net Profit Re Sale of Land’’, which is attached to the notice of appeal and which reads as follows: RECONCILIATION OF NET PROFIT RE SALE OF LAND RE: EXPROPRIATION BY THE FEDERAL GOVERNMENT— DEED 1106499 Date—Nov. 9/54 Expropriation Price $371,260.00 Cost of Land Sold—Purchased Oct. 21/52 $75,391,60 Cost of Land Sold—Purchased Oct. 31/52- 32,004.37 107,395.97 Net Profit_ $263,864.08 14 Time held re lot 525 as per deed 1106499—one year, 1 month and 28 days 44 Time held re lot 527 as per deed 1106499—one year, 2 months and 7 days RE SALE TO INNES EQUIPMENT LTD.— DEED 1109955 Date—Nov. 17/54 Selling Price — $ 50,180.20 Cost of Land Sold—Purchased Oct. 21/52 1- $ 5,206.23 Commission—Westmount Realties- 2,509.00 Notarial Fees 25.00 7,740.23 ” {.;: Net Profit — —- $. 42,439.97 Time held as per Deed 1109955—2 years, 27 days Lot 525! ... OF CANADA— DEED 1007182 Date—May 7, 1953 Selling Price. • $ 67,475.70 Cost of Land Sold—Purchased Oct. 31/52 $ 11,166.88 Commission to Morgan Realties Inc. 3,073.18 Notaries Fees-.. 75.00 Adjustment of Taxes n 24.75 16,640.41 [sic] Net Profit — ….- $ 52,835.29 Time held as per deed 1007182—6 months and 7 days: Lot 525 i RE SALE TO CANADIAN COMSTOCK CO. ... Notarial Fees — 1 250.00 36,788.49 Net Profit I $ 85,711.51 Time held as per deed 1091288—1 year, 9 months, 18 days. ...

The two pieces of equipment were respectively a Sky Ride ’ ’ and a Mine Ride’’, being articles of equipment usually found in an amusement park. ... The purchase of both the ‘ ‘ Sky Ride ’ ’ and the Mine Ride ’ ’ was for such general purpose. ... It was not in the business of operating these rides and on the whole of the evidence, it is not possible to find that the appellant probably, in 1965, had the intention itself to get into the business of operating either or both of the Mine Ride ’ ’ and the ‘ ‘ Sky Ride ’ There is no doubt that the appellant intended in 1965 to receive income in some unspecified way from the operation of these rides. ...

I have even more difficulty with the question whether the remainder of the Unit — that is, the moveable things such as baskets, pans, ete. — are agricultural implements. When, however, I read Itc m 409f as a whole and find that, after enumerating such things as ‘ ‘ Barn... track ’ ’, egg cooling cabinets, hay stack forms, milk coolers, steel stanchions for confining livestock, and brooders, it concludes the enumeration by the words, ‘‘ All other agricultural implements or agricultural machinery’’, I feel constrained to conclude that ‘‘agricultural implements’’ is used in the very broadest of senses and includes almost any apparatus, utensils or instruments used for agricultural purposes. If that is the correct view, almost all, if not all, of the ‘‘Unit’’ (other than things that have been incorporated into the structure) that is not otherwise exempt is exempt as falling within the words ‘ other agricultural implements ’ ’. ...

" ‘2. He was in receipt of. a net income during 1926. of $24,914.50. “*3. ... The income of the wife of William Kennedy, Jr., for the year 1926, was $1,720 made up as follows: Dominion Government Annuity $1,500 Industrial bond interest- 220 " " 8. ... " " Approved and agreed to. ‘ ’ The contention that the wife’s annuity contract issued under the provisions of 7-8 Edward VII, €. 5, was issued free from taxation, may be first considered. ...

Attached hereto is a Certificate executed by Electro- Technical Labs (Alberta) Ltd. dated July 15th, 1958 (Appendix “J”), certifying that the said Resolutions set forth in Appendixes ‘ * H ’ ’ and ‘ ‘ I ” are in full force and effect. 17. ... I also think that the facts of the present case are distinguishable from those in Scammel & Nephew Ltd. v. ... Therefore, the appellant herein could not grant a ‘ concession ”, ‘ franchise ’ ’ or “licence” to itself. ...

Under the Excess Profits Tax Act, 1940, as amended, the " " profits ‘ ‘ of the corporation means the amount of its net taxable income as ascertained under the provisions of the Income War Tax Act, R.S.C. 1927, c. 97, as amended, subject to certain exemptions not here of importance. ... For the taxation year 1947, the relevant permissible deduction was as follows: "5(1) (w) Such amount as the Governor in Council may, by regulation, allow in respect of taxes on income for the year from mining or logging operations. ‘ ‘ The appellant bases its claim on para. ... Burns, a chartered accountant and a partner in the accounting firm of McDonald, Currie & Co. ...

Item No. 23 on page 2 is headed "‘Gross Income from Rentals (give amount received from and address of each property ‘ ‘ and under this there is entered ‘ " net— as per statement attached’’ $2,179.42). ... Counsel for the appellant contended that the words "‘laid out or expended ‘ ‘ were referable to each of the words " " disbursements” and " " expenses. ” In my view, the words "‘laid out’’ are referable to the word "‘disbursements’’ and the word " ‘ex- pended’’ to the word ‘‘expenses.’’ ... The fact that the word 4 " incurred ’ ‘ is not used in the section strongly indicates that the expenses referred to are those that have been paid out. ...

Notwithstanding the words used in the aforesaid Act to designate them, the securities called ‘‘ ‘ preferred shares ’ ’ represent loans ‘ 1 sui generis ’ ’ and in no way correspond to the shares so designated and issued under the limited companies Acts. and seeks to have this appeal dismissed and the decision of the Appeal Board, delivered on June 22, 1951, upheld, all with costs. ... ’ ’ Answer: ‘ 6 That is right. ’ ’ “Q. Whereas the holder of a mortgage loan had the guarantee that the association’s assets were there to pay him? ... Section 20 says, ‘‘ A shareholder-producer shall have only one vote, whatever may be the number of his shares...’’ ...

"" (b) That, in the alternative, if the shares of the said Company were not reduced or redeemed as aforesaid within the meaning of subsection 1 of section 16 of the Income War Tax Act, which the Respondent does not admit but denies, in any case, as a result of the readjustment of the capital stock of the said Domestic Gas Appliances, Limited in accordance with the above mentioned Supplementary Letters Patent, the whole of the said undistributed income in the hands of the said Company at the date of such readjustment was capitalized and is therefore properly taxable in the hands of the shareholders of the said Company pursuant to section 15 of the Income War Tax Act. ff A copy of the Supplementary Letters Patent, and the audited statement of the corporation as of December 31st, 1937 (Exhibit 1), and the audited statement for the year ending December 31st, 1938 (Exhibit 2), were filed. ... The difficulty that arises is due to the word " " capitalize ‘ ‘ which is most inapt. ... What has to be asked and answered in this case is how could they be ‘capitalized’ in accordance with those Acts, without either leaving the holder of the new shares liable to pay them up with new money or sharing out, the profits to the allottees, whether in cash or in account, so that the share-out of the money should be used to pay up the shares. ’ ’ In my opinion a company may add undistributed income to capital so as to (a) issue shares to the extent to which it still has shares authorized but unissued or (b) inerease the authorized capital and issue new additional shares or increase the paid-up capital in each share thereby increasing the par value of each share. ...