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Windsor, a chartered accountant with the firm of McDonald Currie & Company, who were the respondent’s auditors in 1951 and prepared its income tax return for that year, said that Mr. ... And Section 4 provides: ‘ 4. 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. ’ ’ It is emphasized that the taxpayer’s income for any taxation year is his income ‘‘for the year’’ and when that comes from a business, his income for the year is the profit from his business ‘‘for the year’’. ... George Thompson & Co., Ltd. (1927), 13 T.C. 83, and II. & G. Kinemas, Ltd. v. ...

The commissioners have taken this view of the facts, and I cannot say they were wrong. ’ ’ On appeal to the Court of Appeal (reported [1924] W.N. 105) the appeal was dismissed. ... The Commissioners have found — and I think it is the fact — that there was here one business... ... Anderson Logging Co., [1917-27] C.T.C. 210, Lord Dunedin said at page 212: ‘ ‘ It may here be as well to say that their Lordships have not the slightest doubt that the judgment of the Supreme Court on the main question was right, being indeed entirely in conformity with the case of Commissioner of Taxes (Victoria) v. ...

If they are, on the other hand, revenues of a ‘‘business’’, the deductions that may be made in computing " ‘income’’ for the purposes of Part I are not so limited.) ... Article 2.3 further provides that “The Radiologist” agrees “that sufficient coverage shall be provided so that equivalent of one full time Radiologist will be provided for each regular 0,000 examinations per annum... ” thus implying that, if the volume of work should require it, the appellant was to provide the services of more than one radiologist. 6. ... According to Article 12 of the relevant by-laws, such " Chiefs ‘ ‘ were required to " " supervise their respective Departments’’. ...

Employment: The Company shall employ the Manager as General Manager of the Company at and upon and subject to the terms and conditions following. ’ ’ We are acquainted with the stipulations concerning duration and salary, respectively five years at $25,000 per year. ... Again the signatories to this parting indenture were identically those who had signed the "‘employment'' covenant (Exhibit 2) some fourteen months previously, namely: " ‘ Federated Petroleums Limited, per R. ... The income of a taxpayer for a taxation year for the purposes of this Part [Computation of Income] is his income for the year from all sources... and without restricting the generality of the foregoing, includes income for the year from all (a) businesses, (b) property, and (0) offices and employments. ‘ ‘ Section 5 deals further with ‘ income ‘ ‘: "Income for a taxation year from an office or employment is the salary, wages and other remuneration, including gratuities, received by the taxpayer in the year...” ...

Portigal nor did he make use of the firm name of George Loos & Co. ... Portigal himself and to the name of George Loos & Co. as could be retained on Mr. ... In my opinion the nearest of the definitions to the meaning of “tangible” as used in the definition of Class 8 of Schedule B to Regulations is number (3) of the Funk & Wagnall definitions and I do not think that either goodwill or ‘ accounts ’ ’ constitute ‘‘a tangible capital asset’’ within the meaning of that expression in the regulation. ...

(Ste Beuve). — Pop. Figure: Endommager le portrait d’un rival. — Loc. div.: Portrait en pied, Portrait qui représente la personne tout entière. ... Littré: “... Portrait en pied, portrait qui représente une personne entière. ... Portraits littéraires. ’ ’ Funk & Wagnails: “1. A likeness of an individual, especially of the face, produced by an artist in oils, watercolor, etc., or by photography. 2. ...

Next comes, on the longitudinal side of the cardboard container, a chemical and pharmaceutical nomenclature of the various contents compounded in ‘ ‘ Limmits ”; I quote: “Contents: This package contains 6 Limmits. ... S-2, a package of ‘‘ Afternoon Tea, assorted biscuits’’, made by the well-known English manufacturers, Peek, Frean & Co. ... Methionine Ingredient D Reduced Iron Ingredient E ’ ’ Lastly, I cannot detect how the definitions, hereunder, of the word “biscuit ’ could enhance the suppliants’ demands. ...

He says that a judge who has been retired may still quite properly be referred to as a Judge or a retired judge—and that even after his retirement such a judge retains certain powers and may be called upon again to perform the duties of a judge as provided for in section 35 of the Act, which is as follows: ‘ " 35. ... In the sense in which the two words " " superannuation ” and ‘‘pension’’ are here used, I do not think it necessary in this case to draw any distinction between them. ...

The amounts of the several items of expense just mentioned are not in dispute. (1) Premium paid upon retirement of the issue of old bonds $1,104,600.00 (2) Exchange premium paid upon retirement of the issue of old bonds 676,726.00 (3) Expenses in connection with the retirement of the issue of old bonds 25,793.42 (4) Discount on the issue of new bonds: $ 5,000,000 par value at 114 per cent $ 75,000 $10,000,000 " " 4 11 " 400,000 475,000.00 Total $2,282,079.42 I perhaps should here add by way of explanation that there was a provision in the trust deed securing the old bond issue which required the payment of a premium of 4% in the event of redemption before maturity. ... I might point out here that in Canada, under s. 5 (&) of the Act, such reasonable rate of interest on borrowed capital used in the business to earn the income as the Minister in his discretion may allow is permissible as a deduction, and the appellant, in the period in question was allowed a deduction on this account. ... It therefore seems to me to be difficult to say otherwise than that all expenses in question here constituted an outlay on account of capital, within the meaning of the statute, even though on equitable grounds the appellant’s view seems attractive and in many ways quite just, In the case of Archibald Thomson, Black & Co. v. ...

Each bears the brand name as well as the name " " shortening ‘‘ prominently displayed on the labels. ... Graham, another witness for the defendant, also used both liquid and other shortenings and admitted that when she did not use one in liquid form, she used a solid shortening like butter or lard—"‘one of the brands that are sold as shortening. ‘ ‘ Dr. ... Eaton stated that the purpose of hydrogenation is to raise the melting point of the product, and that following hydrogenation ‘‘the product is then commonly called " shortening 9 *’; the peanut oil which is not hydrogenated, he called “a liquid shortening.”’ ...