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Mining claim rentals for 35 sources $ 2,196.64 $ 2,685.11 $ 1,073.82 $ 1,927.05 2. ... ’ ’ The finding may be that an investment has been sold or a trade has been carried on. ... I quote: ': ‘.;.. and whereas The Lake Superior Power Company has eonstructed a large hydraulic power canal at the Town of Sault Ste. ...

C.R. 152 at 157, 158 (affirmed in the Supreme Court of Canada, May 7, 1959, but not reported), in considering a product described as ‘‘ Magic-Pop ’ ’, consisting of popping corn and a small quantity of salt placed in a solidified block of shortening, stated: 4 ‘ In my opinion, the appellant was producing an entirely new article—an article which contained within itself all the ingredients necessary for a householder to use in the preparation of popcorn—in effect a ready-mix ’ article. The mere fact that it was named ‘ Magic-Pop ’ did not by itself result in the making of the new product for any such fancy name could be given to any article without changing its nature. ... It is submitted, also, that as popping corn is the main ingredient of ‘ Magic-Pop ’, the article produced by the appellant should be classified as popping corn. ...

I am of the opinion, however, that the words "‘annual net profits or gain ‘ ‘ in the second line of the definition refer to income whether ascertained or unascertained; and as the word source is used in line 18 it could be argued that it refers to all the following subsections of clause 1 of Section 3 and that the various classifications therein detailed are given as sources of income rather than items of taxable income. ... Rogers (1926), 11 T.C. 508; Robert Addie & Sons Ltd. v. Inland Revenue Commissioner, [1924] S.C. 231 at 235. ... In the absence of any such provision in our Act I cannot give effect to the argument of the appellant’s counsel that it should be allowed to members of Parliament and members of Legislatures in Canada, although, as he urges, it might well be considered ‘ " fair and just. ’ ’ My attention was also directed by counsel for the respondent to section 75(2) of our Act, giving the Minister power to make regulations necessary for carrying the Act into effect, etc. and to authorize the Commissioner to exercise such of his powers in that regard as could in the opinion of the Minister be conveniently exercised by the Commissioner. ...

The above conclusion does no violence even to the language of sec. 3 of the Income War Tax Act which includes as income " * profits directly or indirectly received... from stocks or from any other investment. ‘ ‘ If shareholders, because they are shareholders, are given the chance to buy shares in another company at less than their value, and the selling company then has undistributed profits on hand, then I think sec. 3 is applicable, at least on the assumption that the company is intending to distribute the profits. ... The accountants wrote on 5 October, 1943, to the inspeetor: € 6 is the intention of Timberland Lumber Company Limited to distribute its investment in the shares and debentures of Salmon River Logging Co. ... Appellant tried to account for this willingness by saying they were " " desperate ’ for timber; but his evidence is met by that of their valuer Rodgers who indicated that they paid this price because he valued the shares at even more. ...

The principal paragraph in the usual form of license is as follows: "The licensor hereby grants to the licensee the right to use the inventions described and claimed in said letters patent on the aforesaid machines of the licensee, located as aforesaid including any improvements on said inventions which the licensor may acquire upon the following terms and conditions. ‘ ‘ The licenses are not assignable, and no license passes with the sale of any machine sold by the licensee, but the licensor agrees not unreasonably to refuse to grant a license in the case of a sale of a machine by the licensee. ... The Minister shall have full discretion as to the manner of determining such proportionate part. ‘ ‘ The appellant claims that it does not receive royalty for " * anything used or sold in Canada’’, and that the transactions of the appellant in Canada in connection with the licensing of patents, is not a carrying on of business in Canada within the contemplation of the statute, and that the payments made to the appellant by the licensees are not taxable. ...

Mathers — President and Director Evatt R. Mathers — Vice-President and Director George D. ... Mathers 2 — Evatt R. Mathers 1 — George D. Webb 1 — G. Tidgwell 1 —- P. ... Mathers & Son Limited”’. ...

In this agreement the Settlor was called ‘‘the Investor,’’ and the agreement was known as an “Investment Agreement. ‘ ‘ That agreement was revoked and superseded by another agreement, also known as an “Investment Agreement,” made between the same parties, and dated October 20, 1916, pursuant to which the said fund of $100,000 and all additions thereto made from time to time, was to be held by the said Trustee, subject to the trusts, terms and conditions, therein set out, the said Trustee guaranteeing the payment of the corpus of the fund to such person, persons or corporation as the Settlor might by will or otherwise appoint, at the period of twenty-one years after his decease, with interest at a specified rate. ... By the terms of this agreement the Settlor agreed to assign and set over unto the Canadian Trustee, its suecessors and assigns, all his right, title and interest, in the assets held by the said Trustee under the agreement of October 20, 1916, and certain additional assets, real and personal, which the Settlor desired to make subject to the terms of the same agreement, all of which was transferred to and received by the Canadian Trustee as " " Trustee of Birtwistle Trust. ‘ ‘ The terms and conditions of this agreement need not be mentioned, with the exception of one paragraph, as all other terms of that trust instrument were stated by counsel not to be relevant to the controversy here. ...

Pit #3 Pit #4 Pit #7 Pti #5 East Side Entwistle Lands Clover Bar Lands Lands Sand & Gravel (1960) Ltd. — $19,888.61 $ 67,538.48 $107,289.82 — Clover Bar Land Co. ... In the case of timber limits, similarly to the case of industrial mineral mines, the ‘ residual value ’ ’ of the property is deducted from the capital cost of the limit in fixing the rate basis for the amount of deductible capital cost allowances. ... The appellant also, as of January 31, 1962, transferred all its assets to Twin Bridges Sand & Gravel (1960) Ltd. ...

The computation of the tax in the appellant’s return, which forms part of the documents transmitted to the Registrar of this Court in compliance with section 63 of the Act, is made up as follows: Gross income $90,522.48 Deductions —.... 3,105.00 a. s $87,417.48 Less statutory exemption —.... $2,400 Allowance for 3 dependent chil- dren under 21 years of age at $500 each_.... 1,500 3,900.00 Income subject to tax $83,517.48 Tax 2__... $ 19,170.77 5% additional where net income in excess of $5,000 958.54 $ 20,129.31 The appellant paid this sum of $20,129.31 in due course. On February 18, 1935, the Commissioner of Income Tax sent to the appellant a notice of assessment for the year 1931 altering the amount of the tax; the statement included in the notice is made up as follows: Total income_.. $112,750.76 Deductions...- 3,105.00 $109,645.76 Statutory exemption $2,400 Dependents 1,500 3,900.00 $105,745.76 Tax......._ $ 27,035.93 Additional 5% tax.._...... 1,351.79 $ 28,387.72 Then comes a summary which reads thus: Tax Interest Total Amount levied $28,387.72 $ 1,428.09 $29,815.81 Amount paid on account- 20,129.31 20,129.31 Balance due $ 8,258.41 $ 1,428.09 $ 9,686.50 On February 26, 1935, the appellant’s solicitor wrote to the Commissioner of Income Tax in part as follows: I have just received from Mr. ... In its income tax return for 1931, Trinity Securities, Limited, indicated the nature of its business as ‘‘ Racing and Stud Farm ‘ ‘; in its returns for 1932, 1933 and 1934 it mentioned " ‘Invest- ments.’’ ...

Many of these advertisements include ‘ 1 mouton ” or ‘‘mouton lamb ’ ’ under the general heading of ‘‘Furs’’. ... Moskoff — President of the defendant corporation — viewed its product prior to the commencement of these proceedings. ... Now mouton is offering the customers fur coats at... ” 4 Mouton has made ‘fur coats for all ’ a real possibility’’, ‘‘The mouton coat is more desirable than most other fur coats, Mr. ...