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The directors and agents of New Chamberlain re ceived 20,000 shares @ $1.15. ... O’Connor, Barrister & Solicitor, 320 Bay Street, Toronto 1, Ontario. ... Nicholson & Co. Ltd. and confirmations will be forwarded to you “In Trust”. ...

Final payment to be made within 30 days after satisfactory completion of the entire building and acceptance by the Architect. ‘ ‘ Exhibit B is a contract in which the taxpayer appears as prime contractor. ... Section 1 of the said agreement contains a provision that Form C.C.C. 34A, entitled Department of Trade and Commerce — General Conditions — (construction), shall form part of the present contract. ... M.N.R., [1959] S.C.R. 763, at page 768; [1959] C.T.C. 339, at page 344, observed: [4 ‘. ...

By virtue of this agreement, he accepted, as a withdrawal indemnity in settlement of all the rights which he had or might have in the partnership, the sum of $35,900, payable in the amount of $19,900 by certain ms I whieh he received from the following contracts: Sogefors — $13,900 Métro — 3,000. Stadium — 3,000 and a balance of $16,000, which was specified to be payable when the City of Montreal paid for the Métro plans, out of the share of the fees due to the three other partners on this project in accordance with the terms of a later clause in the agreement. ...

In the year 1952, timber operations started and accordingly Caine Lumber Company produced its claim to a capital cost deduction, pursuant to Section 11(1) (a) hereunder of the Income Tax Act, based upon its own purchase price of $15,000. “11. (1) Notwithstanding paragraphs (a), (b) and (h) of subsection (1) of section 12, the following amounts may be deducted in computing the income of a taxpayer for a taxation year (a) such part of the capital cost to the taxpayer of property, or such amount in respect of the capital cost to the taxpayer of property, if any, as is allowed by regulation, ’ ’ The allowances referred to appear in Part XI of the Regulations, under the respective numeral and heading of 1100 and Schedule C. ... To the best of my understanding it underscored in Section 20(3) (a) of the Act the words *‘... in computing income for that or a previous taxation year...” going on to hold the expressions: ‘ that or a previous taxation year’’ as precluding all claims to subsequent deductions. ... Attorney General: ‘ [By Lord Cairns] I am not at all sure that, in a case of this kind—a fiscal case—form is not amply sufficient; because aS I understand the principle of all fiscal legislation, it is this: if the person sought to be taxed comes within the letter of the law he must be taxed, however great the hardship may appear to the judicial mind to be. ...

V, c. 46), by sec. 8 of the same Act was " " deemed to be applicable to the income for the taxation period 1921 and subsequent periods.” and the appellant contends that the part of the accumulated profits earned before that date is not subject to such taxation, and moreover contends, in the alternative that the whole of that sum is capital and not subject to taxation. ... V, ¢. 46) is that dividends made up of undistributed profits and paid or payable after 1921 as under the circumstances of the case, are liable to tax. ... V, €. 55) passed in 1919 and hereabove recited, declaring that dividends are taxable as income of shareholders in the year in which the same are received or credited. ...

There never has been, and I think there never will be, much difficulty in dealing with any particular case on its own facts and circumstances; and, speaking for myself, I rather doubt the wisdom of attempting to do more.’ ‘‘ In Montreal Coke and Manufacturing Co. v. ... Lord MacMillan said at page 100:— " " Expenditure to be deductible must be directly related to the earning of income. ... The statute in see. 5(b) above quoted significantly employs the expression ‘ capital used in the business to earn the income’, differentiating between the provision of capital and the process of earning profits. ’ ’ In this case the company is not engaged in financial operations but is engaged in the construction business. ...

This the appellant forwarded to the Director of Income Tax at Calgary on April 11, 1953, with a letter prepared by the accountant but signed by the appellant himself, in which he expresses disagreement with the figures in what is referred to as " the net worth statement set out on VZA 70977”. ... In making the reassessment, the Minister apportioned the $14,733.65 over the four years as follows: 1948 $4,125.42 1949 — $2,210.05 1950 — $5,156.78 1951 — $3,241.40 and assessed the appellant accordingly. ... Section 47 of the Income War Tax Act, under Which the Minister proceeded in respect of the appellant’s income for the year 1948, is as follows: " "47. ...

Section 59 sets out the duties of the Minister as follows: " " 59. ... Section 66 then sets out the Court's appellate jurisdiction as follows: " " 66. ... All the Court is concerned with is the correctness of the ‘‘assessment under appeal. ’ ’ That question is solely a judicial one. ...

Even if it were, it cannot be said that ‘‘... no part of the income... is paid or payable to any... shareholder...”’ ... Section 25 provides in part as follows: ‘ ‘ The general meeting shall decide, in accordance with such statement, the amount of the profits to be allotted. ... Province of Que.-.-.- 350.00 Printing & Stationery 287.16 Telephones & Telegraphs 255.52 Advertising, Insurance, etc. 208.69 Fees: Board of Trade, Trade Marks, ete 150.00 Travelling Expense 155.15 News-Letter Expense 59.62 Other Expenses 994.44 8,584.66 December 15th, 1947 — Balance as detailed below $32,279.40 Bonds $29,289.57 Receivable from Plant Account 2,989.83 $32,279.40” The revenue of $10,657.13 described above as being received from members is referred to by Mr. ...

" " Saint-Malo” 792.47 Depreciation recaptured 5,962.20 Legal fees 1,505.34 $71,410.30 Less: Portion of unabsorbed 1948 loss $7,803.03 Unabsorbed 1950 loss 7,240.39 $15,043.42 $56,366.88 Less reported loss for 1951 $38,533.32 Net taxable income $17,833.56 The appellant objected to the assessment, with the exception of the item of $1,505.34 for legal fees, but the Minister confirmed it. ... It would seem that the purchaser had inspected La Grande Hermine ‘ ‘ at Bremerhaven and had found her condition to be satisfactory. ... There would be no doubt concerning the appellant’s contention if it was established that "‘the proceeds of the disposition of the two vessels to the extent that they were used for replacement under conditions satisfactory to the Canadian Maritime Commission. ‘ ‘ What is the evidence on this point? ...