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See Plaxton & Varcoe’s Dominion Income Tax, 166. Having said so much I gather from what was said by the respective counsel at bar that they will adjust among themselves the figures of the assessment upon the principle disclosed by the judgment. ...

App. 597, and Singer +. Singer, Can. 8.C.R. vol. 52, p. 447, reject this view and hold that the income belongs to the widow absolutely subject only to an obligation to provide, in her discretion, for the support and maintenance of the children. ...

The method by which the Minister arrived at the cost of $305.90 for the one and one-half lots sold is shown on the statement attached to the re-assessment entitled ‘‘ Evaluation of land costs.” It was first assumed that the cost of the University site of 160 acres was the face value of the 1,000 shares having a par value of $100 each issued in payment therefor — a total of $100,000. ... Thompson, a chartered accountant of Montreal and senior partner in Canada of another well-known accounting firm, Peat, Marwick & Company. ...

. • Sumptuous meals, under a tropical sky or in air conditioned comfort. • Sparkling entertainment... steel drum bands, Bahamian dancers, limbo meringue, bossa nova, native night clubs. e An emerald beach, a jade-colored pool. e Water sports, lawn sports, golf, horse racing. @ Sightseeing, shopping and sunning! ... Sometime later each participant was presented with a souvenir brochure of the trip — the opening page of which read as follows. ...

In 1947 the Robert Reford Company Limited (hereinafter referred to as the Company ’ ’) owned lands and buildings, the original cost of which had been $433,433 on which the Company had been allowed prior to 1947 a depreciation allowance of $208,289.73 pursuant to Section 6(1) (n) of the Income War Tax Act. ... Anaconda American Brass Ltd., [1956] A.C. 85 at page 100 [[1955] C.T.C. 311]: “The income tax law of Canada, as of the United Kingdom, is built upon the foundations described by Lord Clyde in Whims ter & Co. v. ... I find therefore that the Company did not incur a loss of $148,433 from the sale of the property in question in 1947 but rather realized a capital profit of $59,856.73 and that the assessment of appellant’s income for the 1962 taxation year as made in the notice of re-assessment dated January 30,-1968 is correct and appellant’s appeal against this assessment is therefore dismissed, with costs. 1 * Section 82(7) reads as follows: 82. (7) For the purpose of subparagraphs (iii) and (iv) of paragraph (a) of subsection (1), (a) where depreciable property of a taxpayer (as defined by subsection (5) of section 20) has been disposed of in 1949 or a subsequent taxation year, the capital loss arising from the disposition shall be deemed not to be more than the actual capital cost of the property to the taxpayer minus the capital cost thereof as determined for the purpose of section 20, and (b) where depreciable property of a taxpayer (as defined by subsection (5) of section 20) has been disposed of in 1949 or a subsequent taxation year, the capital profit or gain arising from the disposition shall be deemed not to be more than the proceeds of the disposition (as defined by the said subsection (5)) minus the capital cost of the property to the taxpayer as determined for the purpose of section 20. ...

., supra, by Martland, J. at p. 354 [p. 222]: “... whether a venture such as we are now considering is, or is not, ‘in the nature of trade”, is whether the operations involved in it are of the same kind, and carried on in the same way, as those which are characteristic of ordinary trading in the line of business in which the venture was made.” ... There was an action for commission, initially by Marriette Agencies Ltd. and later amended to Hopper & Jamieson Limited, of which action there were put in as exhibits an examination for discovery of Hutchinson (Ex. ... R-4, p. 3) Hutchinson testified that he gave a listing to Gillanders Realty at $440,000 and testified, ‘‘ Yes, I told him that I wanted $425,000 net to Georgia Gulf Estates and that we wanted cash to the mortgage’’. ...

Les porteurs d’actions privilégiées n’ont pas le droit d’assister ni de voter aux assemblées de la société. ’ ’ Kn 1944, vu que la société progressait, il fut décidé d’étendre ses activités et d’entreprendre la fabrication du lait en poudre. ... Dans le texte de l’article se trouvent les paragraphes suivants: ‘‘Pendant cette campagne d’emprunt qui débutera le 1er juin 1946 pour prendre fin vers le 1er octobre de la même année, la Société Coopérative Agricole du Canton de Granby émettra pour la somme de $275,000 de parts privilégiées dont la valeur nominale au pair sera de $50 la part, portant intérêt non cumulatif au taux de 5 %. ... Je cite: ‘ 37. La nouvelle société coopérative agricole doit répartir son capital-actions conformément au paragraphe 7 de l’article 5 de la présente loi, sur une base de cinq actions de dix dollars ou de dix actions de dix dollars. ...

Vers la fin de l’exercice financier, l’intimée, connaissant le prix net de la récolte, détermina le montant du surplus de ses opérations et passa, le 6 octobre 1947, la résolution suivante: ‘* Proposé par Euclide Beaudry, secondé par J. ... La preuve m’a convaincu que, règle générale, à la fin de l’année financière de la Société, si le montant dépassait le chiffre jugé nécessaire à la continuation de ses activités, l’exédent, ou à peu de chose près, était distribué aux membres planteurs au prorata des montants crédités à leurs comptes respectifs à la " * réserve pour planteurs’’. ... It was assessed for income under the Income War Tax Act (R.S.C. 1927, c. 97) in respect of certain sums which it retained, from the gross returns of sale of grain, as a ‘commercial reserve ’ and as an ‘elevator reserve’. ...

"‘What is the line which separates the two classes of cases may be difficult to define, and each case must be considered according to its facts; the question to be determined being— Is the sum of gain that has been made a mere enhancement of value by realising a security, or is it a gain made in an operation of business in carrying out a scheme for profit making. ‘ ‘ The Court came to the conclusion that the sale of the property in question was a proper trading transaction. ... He said of its transactions in the raw sugar futures market: " " I think it is difficult to disassociate them from what took place in the first instance.” ...

S.C. 1948, ¢. 52, it claimed a deduction from its 1951 ineome in respect of the loss incurred by it on its operations for the year 1952. ... In applying the test so expressed to the facts before him, Rowlatt, J., said at p. 276: “... ... One might usefully paraphrase the last clause of the passage above quoted to apply it to this case as follows: ‘‘... that, having been allowed a deduction for wear and tear in the name of capital cost allowance, the respondent is not entitled to a deduction in the name of repairs to restore the same property to its original condition.’’ ...