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Subject to the other provisions of this Part, income for a taxation year from a business or property is the profit therefrom for the year. ’ ’ And Section 127(1)(e), later Section 139(1) (e), defines ^business ’ ’ as follows: “(e) business’ includes a profession, calling, trade, manufacture or undertaking of any kind whatever and includes an adventure or concern in the nature of trade but does not include an office or employment;” The distinction between profits that are subject to income tax and those that are not, together with the test to be applied in determining on which side of the line they fall, was clearly stated in the well-known case of Californian Copper Syndicate (Limited and Reduced) v. ... Wolf Goldstein who took a % share, leaving a /6 share for the respondent. ...

I believe it would be in the fall of ’55 after they were staked. ’ ’ As appears by the two letters dated June 1 and 2, 1955 (Ex. ... The letter was admitted under reserve of objection and reads as follows: ‘ ‘ 70 Front Street Oakville, Ontario, C. ... Wheeler will be dismissed with costs. 1 * The evidence makes no reference to any relationship which existed between Raglan Nickel and Raglan Mining Co. ...

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. ...

Nor was it contemplated by Section 1201 of the Regulations that the expression ‘‘ where the taxpayer operates an oil or gas well ’ ’ should confine its benefit to the operator of a single well. ...

M.N.R., 29 Tax A.B.C. 190, when a majority of the full Board as it was then constituted, although it dismissed the appeal, gave very full and complete consideration to the possibility that Section 1101(1) of the Regulations might be ultra vires although this argument had not been raised before them, and reached the conclusion that this was an issue " which might well be dealt with if either of the parties considers it advisable to proceed to the Exchequer Court by way of appeal”.! ... Section 20(5) (e) defines " ‘ undepreciated capital cost’’ to a taxpayer of depreciable property of a prescribed class for the purposes of Section 20 " ‘ and regulations made under paragraph (a) of subsection (1) of section 11”. ... Touzeau and the reasons therefor, I have reached the conclusion that Section 1101(1) of the Regulations is a proper exer- cise of the implied power to prescribe classes by Order in Council within the scope of the enabling power of the Income Tax Act, and while it does limit the effect of Section 20(2) of the Act in the situations to which it applies, it is not in contradiction to this section and hence is not ultra vires. / Having reached this conclusion, appellant’s appeal must succeed but the Minister has agreed, in this event, to reconsider and, if necessary, re-assess respondent’s income for 1963 in order to allow respondent such further capital cost allowance under Section 11(1) (a) of the Income Tax Act as it may; claim and the Minister may permit on the ‘basis that Section: 1101(1) of the Regulations i is intra vires. ...

The expenditures fall into two classes: (a) the expense of replacing what are, in effect, floors and walls of cargo-carrying holds in certain ships and of incidental work in respect of the apparatus or members whereby such floors and walls were joined to the outside surface or ‘ skin” of the ship—such work having been made necessary by the wear and tear arising out of the loading, carrying and unloading of cargoes; and (b) the expense incurred in the replacement of boilers in one of the ships. ... The appellant is to have its costs of the appeal. 1 "' Even if repairs are neglected so long that they temporarily pre vent the continuance of the business, they are deductible “when the expenditure is made”, and not “when in the prudent carrying on of the business it ought to be made”. ...