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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.” ...

The reason why the parties are agreed on the view that the word " goods ‘ ‘ in these provisions must be read as including "electricity’’ is that, by virtue of Section 32(1), the tax imposed by Section 30 does not apply to the sale or importation of the e articles” mentioned in Schedule III, and one of the "‘articles’’ mentioned in that schedule is ‘‘electricity’’ (see paragraph 3 of Part VI of Schedule III). ... The Board then said that it, faced with these two different stresses, ‘ goes beyond the mere concept of transfer and accepts that of production’’. ... Research-Cottrell (Canada) Ltd. et al. (1968). 2 * According to the Petit Larousse, the word "électricité" is a “Nom donné à l’une des formes de l’énergie”. 3 * Indeed, that is what the respondent’s charter authorizes it to do. ...

Young 450 shares Rolka 450 “ Atkinson 100 “ 1,000 The following is an extract from these Minutes: “Mr. ... Ltd. to Young $ 500.00 per lot Sale by John H. Young to Nelmar Realty Limited $1200.00 “ “ Sale by Nelmar Realty Limited to Rolmae Construction Company Ltd. $1500.00 “ ‘* ” From that letter it is abundantly clear that in respect of that sale, at least, a plan had been arranged even before Young secured his deed by which the lots would be immediately sold by him to Nelmar Realty, which company, in turn, would sell them to Rolmac Construction Co. ... Reference may also be made to Miron & Frères Ltée v. M.N.R., [1955] S.C.R. 679; [1955] C.T.C. 182. ...

On a suggéré au gouvernement de le changer s’il ne trouvait pas ça correct, s’il trouvait le montant déraisonnable et alors on était prêt à mettre un autre montant. ’ ’ Conformément au contrat intervenu entre l’appelante et son principal actionnaire, elle lui versait les montants suivants: 1952 $10,730,53 1953 $10,210.05 1954 $ 7,355.90 1955 $ 7,686.82 1956 $ 8,611.61 L’appelante chargea ces montants comme dépenses d’opérations et les déduisit du revenu découlant de ses ventes pour les années ci-haut mentionnées. ... C’est là que l’appelante aurait consenti par la résolution ci-dessus à lui venir en aide en lui faisant des avances ‘ ‘ comme acompte sur des factures à venir’’. ... Quebec Boot & Shoe Regd. est une raison sociale appartenant à un M. ...

The first cheque bears above the words “To the Royal Bank of Canada, Montreal,’’ printed at the bottom of the left side of the cheque the words " " Account of services, ‘ ‘ and the second one bears in the same position the words ‘‘ Balance due on account of services rendered in connection with acquisition of La Salle, et al.” ... Trudeau is mentioned in this return; opposite his name, in the column headed ‘“Wages, salary, commission, bonus or other remuneration paid during the calendar year ended 31st December, 1937’’ (ought to be ‘ ‘ 1932”), under the subheading ‘‘Total,’’ appears the sum " " $25,000.” ... Trudeau accepted the two cheques without any protest regarding the notes ‘‘ Account of services’’ and “Balance due on account of services, etc.,” written thereon, at least as far as disclosed by the evidence of record, and endorsed and cashed them. ...

A2) — Freda/1494 (Ex. A3 No. 1494 (Ex. A6) Account No. 1494. Under (Ex. ... There is some evidence, therefore, that the appellant’s husband was in business and that the appellant through the agency of her husband may have been engaged in ‘ ‘ an adventure or concern in the nature of trade ’ ’ within Section 139(1) (e). ... M.N.R., [1964] C.T.C. 519 at 921, Cattanach, J. stated: “It follows that in my view, when a person embarks on an adventure in the nature of a money lender’s trade and earns a similar profit the profit he acquired is a profit from an adventure in the nature of trade. ’ ’ In the present case, the appellant’s husband, who entered into the transactions as the appellant’s agent, was not called as a witness to prove the transactions, their nature, the nature of his business and the extent to which the appellant’s transactions were intermingled in his business. ...

Nowhere in the Act is it provided that the word 1 ‘ person ’ ’ where it is used, shall include a corporation. ... The corporate name was printed on the bills in bold type and below it the words ‘‘ Medical Clinic of Dr. ... Cheques drawn on the Company’s bank account were signed “ L. C. Kindree M.D. ’’ beneath which manual signature the words, “Medical Clinic: Squamish Holdings Ltd.” were either stamped or written. ...

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’’.’ ...

Gifts with reservations of benefits are deemed to be included in a “ succession ‘ ‘ under:— “3 (1). ... The corresponding provisions of the other Acts mentioned do not contain the words ‘‘or by a trustee for the donee ‘ ’. ... The deed of settlement (1930) with the amendments under the agreement (1937) further provided:— " ‘2. ...