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Paragraph 5 of a Memorandum of Readiness, eased the evidence in stating that ‘‘... ... A-3, for instance), with the modest rank of ‘‘ Assistant’’, the academic personnel of the Faculty of Dentistry. ... (la) ‘employee’ includes officer; (m) ‘employment’ means the position of an individual in the service of some other person (including Her Majesty or a foreign state or sovereign) and ‘servant’ or ‘employee ’ means a person holding such a position; (ab) ‘office’ means the position of an individual entitling him to a fixed or ascertainable stipend or remuneration and includes a judicial office, the office of the Minister of the Crown, the office of a member of the Senate or House of Commons of Canada, a member of a legislative assembly, senator or member of a legislative or executive council and any other office, the incumbent of which is elected by popular vote or is elected or appointed in a representative capacity and also includes the position of a corporation director; and ‘officer’ means a person holding such office.’’ ...

In reassessing the appellant, the Minister had added to his declared income the sum of $979 said to be income arising from an original gift to his wife, said income being made up as follows: (a) Interest Kern mortgage $300.00 (b) Dividends from 100 shares New York, New Haven and Hartford Railway 679.00 Total $979.00 In so assessing the appellant, the Minister relied as he now does on subsection (1) of Section 21 and subsection (3) of Section 22 of The Income Tax Act, which were as follows: ‘ ‘21. (1) Where a person has, on or after the 1st day of August, 1917, transferred property, either directly or indirectly, by means of a trust or by any other means whatsoever, to his spouse, or to a person who has since become his spouse, the income for a taxation year from the property or from property substituted therefor shall be deemed to be income of the transferor and not of the transferee. 22. (3) For the purpose of this section and section 21, where a person who did own or hold property has disposed of it and acquired other property in substitution therefor and subsequently, by one or more further transactions, has effected one or more further substitutions, the property acquired by any such transaction shall be deemed to have been substituted for the property originally owned or held.” ... Paragraph (c) 18 headed “Gift”, and the answer recorded is ‘‘ Main Street house Gift from my husband Sold 1952 for $11,000’’. ... The proceeds of approximately $10,500 received from the sale of the Main Street property can therefore be accounted for to the following extent: (a) $2,500 used in the purchase of 200 shares of Brazilian stock in January 1952; (b) $2,800 used in payment of the bank loan of a like amount on July 17, 1952; » (c) $5,000 advanced by way of mortgage loan to Kern on November 10, 1952. ...

Section 3(1) of the Income War Tax Act reads as follows: ‘{" Income’ means the annual net profit or gain or gratuity, whether ascertained and capable of computation as being wages, salary, or other fixed amount, or unascertained as being fees or emoluments, or as being profits from a trade or commercial or financial or other business or calling, directly or indirectly received by a person from any office or employment, or from any profession or calling, or from any trade, manufacture or business...”’ ... I quote from her Examination of Discovery: 4 " 48. Q. Did you study the real estate market? ... ‘ ‘ This decision was approved in the Judicial Committee by Lord Dunedin in Commissioner of Taxes v. ...

George Thompson & Co. Ltd. (1927), 13 T.C. 83, the question was whether the respondent company’s business, which consisted of ship-owning and underwriting, constituted one business or two separate businesses. ... George Thompson & Co., Ltd. (1927), 13 T.C. 83, and H. & G. Kinemas, Ltd. v. ...

Nous y pourrions voir avec un brin d’imagination, une paraphrase, sans doute insoupçonnée, du dicton ‘ 1 Once a Britisher, always a Britisher’’, ‘‘négociant la, négociant partout’’. ...

An appeal to the Income Tax Appeal Board was allowed, the Board being of the opinion that the ‘‘ Act to Insure the Progress of Education” did not impose a corporation tax, and that the Governor in Council in enacting P.C. 5948 exceeded the powers conferred on him by paragraph (o) of Section 6(1) of the Income War Tax Act, and that it was therefore ultra vires. ...

An appeal to the Income Tax Appeal Board was allowed, the Board being of the opinion that the ‘‘ Act to Insure the Progress of Education” did not impose a corporation tax, and that the Governor in Council in enacting P.C. 5948 exceeded the powers conferred on him by paragraph (o) of Section 6(1) of the Income War Tax Act, and that it was therefore ultra vires. ...

An appeal to the Income Tax Appeal Board was allowed, the Board being of the opinion that the ‘‘ Act to Insure the Progress of Education” did not impose a corporation tax, and that the Governor in Council in enacting P.C. 5948 exceeded the powers conferred on him by paragraph (0) of the Income War Tax Act, and that it was therefore ultra vires. ...

An appeal to the Income Tax Appeal Board was allowed, the Board being of the opinion that the ‘‘ Act to Insure the Progress of Education” did not impose a corporation tax, and that the Governor in Council in enacting P.C. 5948 exceeded the powers conferred on him by paragraph (0) of Section 6(1) of the Income War Tax Act, and that it was therefore ultra vires. ...

Jacques and/or from the Canadian Broadcasting Corporation or their duly appointed Architect for the Building Project known as CBC Radio & T.V. ... & Ad. 833); nor, in proceedings between a party and a stranger, will the former be estopped, since there would be no mutuality.” ... As one witness stated, the name ‘‘Brett, Ouellette and Smith’’ or ‘‘ Brett, Ouellette and Jones’? ...