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The first venture of the appellant was to purchase shares in a company known as Highwood Petroleum & Natural Gas Co. ... Ltd. of the first part, Highwood-Sarcee Oils Ltd. of the second part (the appellant company), Clark, Martin & Co. ... " " The well in Saskatchewan was completed and abandoned in the Fall of last year after every precaution had been taken to exploit all its possibilities. ...

The Board has met such a plea on several occasions and it would appear to me to open wide the doors to tax evasion if such an unsupported statement were accepted as meeting and overriding the presumption of validity attributed to an assessment by the Minister. ‘ ‘ The appeal is dismissed with costs. ...

At all material times also the appellant, Morgan Securities Limited, was a wholly owned subsidiary of Houston & Company Limited, brokers and underwriters, a member of the Toronto Stock Exchange, or of the individual partners of the predecessor partnership firm, Houston & Company. ... Tetlaw, controlling shareholders of Houston & Company Limited, and partners in the predecessor partnership firm of Houston & Company, caused a private Ontario company to be incorporated under the name of Parkton Limited, and then caused Parkton Limited in September 1955, to buy all the shares of three car transport companies from one Harold Hoare, namely Gillson Automobile Transport Limited, Roadway Carriers Limited, and Automobile Transport Limited for $690,000 which was paid for as follows: firstly, by a note to Harold Hoare for $65,000 and by issuing and delivering 250,000 first preference shares of Parkton Limited to him and by paying him $375,000 in cash. ... Thus subject to the note of $65,000 and the $300,000 first preference shares of Parkton Limited held by Harold Hoare, at the date of this acquisition the major shareholders of Houston & Company Limited, or its predecessor partnership, controlled Parkton Limited through the appellant, that is to say James Houston, Reginald H. ...

The appellant was, prior to 1954, engaged in the business of building houses — some under contract for others and some on his own account for re-sale. ... Early in 1954, the appellant caused a company — Stephen Sura Ine. — to be incorporated, and from that time on, the appellant carried on for the account of the company the business that he had previously carried on for his own account, with this additional feature, that, when he — as Stephen Sura — found land that he decided should be acquired to be used in the company’s house-building business, he acquired on his own account and so held it until the company was ready to acquire it and use it, at which time he sold it to the company at its cost to him. ... Having reached that conclusion, I must conclude, as President Thorson did in the Taylor case, that the property having been acquired in the course of an operation of a business character, a profit from its disposition, at least in the circumstances under which the land was sold in this case, is a profit from a ‘‘ business’’ within the extended meaning of that word as used in the Income Tax Act. ...

That in the alternative if the said gain is found to have arisen from the sale of inventory in the form of land belonging to Bel-Air Builders Company, then no part of such gain could have constituted taxable income in the hands of the Appellant, because it resulted from a slump transaction. ’ ’ and by adding a new paragraph 7 to Part B of the said Notice of Appeal which reads as follows: “That the sale of the residue of the land belonging to Bel-Air Builders Company to the Crown took place before Section 85E of the Income Tax Act came into effect.’’ ... The appellant urges that although the beginning of Rule 115 appears to be permissive, the latter part seems to be mandatory, as it would appear that any amendment‘ ‘ necessary for the purpose of determining the real question or questions in controversy between the parties’’, should be allowed. ... There is no injustice if the other side can be compensated by costs; but if the amendment will put them into such a position that they must be injured, it ought not to be made. ’ ’ In the case of Stewart v. ...

The computation of 1955 taxable income of the company as determined by the re-assessment is: Taxable income declared by company $ 789.76 Capital cost allowance claimed by com pany $4,570.17 Capital cost allowance as determined by the Minister 104.67 Add to income as declared 4,465.49 Taxable income as revised and as assessed $5,255.25 Benjamin Richard Steen, the president of the company, testified respecting the 1946 acquisition of the property. ... At the time of the sale the rentals being derived from the buildings were: Zenith Electric Supply — $2,000.00 per month Herbert A. Watts Limited 855.00 u “ Stephen Sales Limited 541.66 u *: Trevelyan Manufacturing Co. 225.00 ‘:‘ L $3,621.66 The annual gross income approximated $44,000.00 and the annual net income, before administration expense, was in the vicinity of $22,000. ...

O’Brien, Home, Hall & Nolan] instituted legal action before the Superior Court of the Province of Quebec against the Attorney General of Canada [Case No. ... Vide p. 24 of the official report: Ip. 160] ‘ ‘ It satisfies, I think, the criterion laid down by Lord Cave in British Insulated v. ... Goldsmith Smelting & Refining Co., [1954] S.C.R. 55 at 57; [1954] C.T.C. 28 at 31. ...

Jens credits a large proportion of the 1957 ‘‘ premium business” listed on Exhibit 11, at no less than $66,250. ... Of greater significance, I presume, in respondent’s appraisal, three columns of this audit sheet (Ex. 8), labelled ‘‘Provision for Income Taxes’’, read as follows: 1950: $17,616.27 — 1956: $94,559.34 — 1957: $43,975.94. ... At the material time, Campbell was one of MacMillan & Bloedel’s lumber buyers, since promoted to head buyer. ...

Cost of development work, approximately $ 280,000 2. Cost of stripping overburden to March, 1962 $1,271,636 3. ... Accordingly to a revolutionized mining technique, the noun “mine in Black’s Law Dictionary, 1951, 4th ed., p. 1146, is defined as: ‘© ‘Mine’. ... Previously, the ‘‘ works manager” of both Canadian Gypsum and Fundy Gypsum, engineer Michael E. ...

Article 1257 provides as follows: "All kinds of agreements may be lawfully made in contracts of marriage, even those which, in any other act inter vivos, would be void; such as the renunciation of successions which have not yet devolved, the gift of future property, the conventional appointment of an heir, and other dispositions in contemplation of death. ‘ ‘ Alfred Curzon Dobell and his wife Helen Maffett are separate as to property in virtue of their marriage contract. ... The legislation which is now sought to be applied originated in 1917, years after the ante-nuptial contract; and subsection 4 of section 4 of 7 & 8 Geo. ... It is not a debt under c. 8(2) (a) because it was not created ‘‘for full consideration in money or money’s worth ’ ’. ...