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" ‘2. He was in receipt of. a net income during 1926. of $24,914.50. “*3. ... The income of the wife of William Kennedy, Jr., for the year 1926, was $1,720 made up as follows: Dominion Government Annuity $1,500 Industrial bond interest- 220 " " 8. ... " " Approved and agreed to. ‘ ’ The contention that the wife’s annuity contract issued under the provisions of 7-8 Edward VII, €. 5, was issued free from taxation, may be first considered. ...

" " 11. That the oil produced by Vulcan Oil Limited is not in fact physically divided by the Company, nor is it sold in two distinct portions of 90 per cent and 10 per cent, but the whole is handled in bulk. ... " " 12. That the Appellant, or her Agent, has in fact from time to time entered upon and viewed the operations and workings of Vulcan Oils Limited as to the operations of the mining of oil on the property. ^13. ... East wood (1858) 2 Hurlstone & Norman. 811; Commissioners of Inland Revenue v. ...

Item No. 23 on page 2 is headed "‘Gross Income from Rentals (give amount received from and address of each property ‘ ‘ and under this there is entered ‘ " net— as per statement attached’’ $2,179.42). ... Counsel for the appellant contended that the words "‘laid out or expended ‘ ‘ were referable to each of the words " " disbursements” and " " expenses. ” In my view, the words "‘laid out’’ are referable to the word "‘disbursements’’ and the word " ‘ex- pended’’ to the word ‘‘expenses.’’ ... The fact that the word 4 " incurred ’ ‘ is not used in the section strongly indicates that the expenses referred to are those that have been paid out. ...

Peacock — $110,000 To Isabel Manley — $110,000 To Donald George Ewen — $ 55,000 To Kenneth Ewen — $ 55,000 Total — $550,000 Purcell shall pay $150,000 on account of the said sum of $550,000 by April 15, 1956 as follows:— To Joseph Sedgwick — $ 60,000 To Kenneth W. Peacock — $ 30,000 To Isabel Manley — $ 30,000 To Donald George Ewen — $ 15,000 To Kenneth Ewen — $ 15,000 3. ... Under the 1949 agreement the lenders became partners in the firm of Jack Purcell & Company. 2. ...

—Sales Feb. 1, 1951 to June 12, 1952—43,500 shares $39,990.00 Less: Cost— 10,000 shares @8^ $ 800.00 33,500 “ @ 71AM 2,512.50 36,677.50 Adjusted Taxable Income assessed $71,823.35 For 1953: Taxable Income previously assessed_. $ 7,417.12 Add: Proceeds from sale of shares of Inland Natural Gas Co. ... Col lieries (Dunsmuir) Ltd. which were acquired through participation with Ross Whittali Ltd. in purchase from Sunray Oils: 1,000 shares $ 9,185.83 Less: Cost at $ per share 3,500.00 5,685.83 Adjusted Taxable Income assessed I 845,7 63.69 As will be noted from the above, during the year 1952 the appellant was assessed for further taxable income on the net proceeds of the sale of St. ... John Oil & Gas Co. Ltd.) For the reasons given in the case of N orman R. ...

Strachan 666 102 2.17 — — C. A. Ebner — — — 3,231 33 17.0 W. E. Jacobson 333 81 11.7 1,425 14 7.5 3,000 549 100% 19,008 190 100% The respondent in its assessment assumed that the appellant and Canadian Mouldings Limited were both at some time in the taxation year 1961 controlled by the following group of persons in Schedule “D” hereunder, which comprises all the shareholders of both corporations who are common to both companies and therefore excepting therefrom A. Strachan who holds shares in Canadian: Mouldings Limited only and. ©, A. ... LIMITED CANADA LIMITED Common Preferred Common Preferred Shareholder_ Shares Shares % Shares Shares % F. ...

Poitras et al., 44 R. de J. 63 at 74, where the importance of the intention of the parties is stressed and where, in this connection, the following admonition is found: “On ne doit par recourir aux autorités anglaises, vu qu’il semble que les principes du droit anglais sur ce point ne sont pas semblables aux nôtres. ’ ’ Planiol & Ripert, Droit Civil, Vol. 11, p. 236: “981 5° aux quatre éléments énumérés ci-dessus on en ajoute généralement un cinquième consistant dans Vaffectio societatis, c’est-à-dire l’intention de former une société ou, de façon plus exacte et plus précise, la volonté de coopérer en acceptant délibérément certains risques. ... Bau: ‘ Le contrat de société exige comme conditions essentielles de sa formation l’intention des parties de s’associer, une chose mise en commun, et la participation aux bénéfices et aux pertes de l’entreprise. ’ ’ ’ Furthermore, in endeavouring to ascertain the true intent and meaning of the type of agreement here in issue consideration, I think, must be given to such additional factors as the language in which it is couched; whether and to what extent mutually shared elements of speculation or risk exist; the extent of inequality, if any, of the authority which it vested in the parties; and the de facto conduct of the parties in giving effect to the agreement. ... (p. 186): ‘‘ Après avoir examiné le contrat du 1 er septembre 1912, J suis d’avis que c’est un contrat de société. ...

The two pieces of equipment were respectively a Sky Ride ’ ’ and a Mine Ride’’, being articles of equipment usually found in an amusement park. ... The purchase of both the ‘ ‘ Sky Ride ’ ’ and the Mine Ride ’ ’ was for such general purpose. ... It was not in the business of operating these rides and on the whole of the evidence, it is not possible to find that the appellant probably, in 1965, had the intention itself to get into the business of operating either or both of the Mine Ride ’ ’ and the ‘ ‘ Sky Ride ’ There is no doubt that the appellant intended in 1965 to receive income in some unspecified way from the operation of these rides. ...

Under the Excess Profits Tax Act, 1940, as amended, the " " profits ‘ ‘ of the corporation means the amount of its net taxable income as ascertained under the provisions of the Income War Tax Act, R.S.C. 1927, c. 97, as amended, subject to certain exemptions not here of importance. ... For the taxation year 1947, the relevant permissible deduction was as follows: "5(1) (w) Such amount as the Governor in Council may, by regulation, allow in respect of taxes on income for the year from mining or logging operations. ‘ ‘ The appellant bases its claim on para. ... Burns, a chartered accountant and a partner in the accounting firm of McDonald, Currie & Co. ...

.: “‘ Assessments will be reported and approved on the above basis.’’ ... Para. 1 says " 1 that in respect of timber cut in the taxation year... operators be given a special allowance. ‘ ‘ Para. 5 says ‘‘that the special allowance be not granted in respect of pulp-wood... operations.” Para. 1 uses the word ‘‘operators’’; para. 5 the word " " operations. ” It is evident that out of general logging operations an exception of pulp-wood operators is made. ...