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La clause du dit testament qui fait la base du présent litige se lit comme suit: “Je donne et lègue tous mes biens meubles et immeubles, ainsi que mes polices d’assurance sur ma vie, à mon épouse Yvette Bernier, laquelle je nomme mon exécutrice testamentaire, la rendant indépendente de tout tuteur qui serait nommé à mes enfants. ’ ’ La succession du dit Lucien Frégeau s’ouvrit à son décès, le 4 juin 1953. ... Voyons quels sont les termes de cette disposition de la loi (R.S.C., 1952, chap. 89). “3. (1) A ‘succession’ shall be deemed to include the following dispositions of property and the beneficiary and the deceased shall be deemed to be the ‘successor’ and ‘ predecessor’ respectively in relation to such property: (h) money received or receivable under a policy of insurance effected by any person on his life, or effected on his life by a personal corporation, whether or not such insurance is payable to or in favour of a preferred beneficiary within the meaning of any statute of any province relating to insurance, where the policy is wholly kept up by him or by such personal corporation for the benefit of any existing or future donee, whether nominee or assignee, or for any person who may become a donee, or a part of such money in proportion to the premiums paid by him or by such personal corporation, where the policy is partially kept up by him or by such personal corporation for such benefit;” Dans la cause qui nous est soumise il a été établi que le testateur a assuré sa propre vie. ...

In other words it is an attempt to cover what, in the vernacular of the business, is referred to as a “ grubstaking ” arrangement. ...

Appellant and his partner received a grant of $60,000 under the provisions of the Cheese and Cheese Factory Improvement Act, R.S.C. 1952, ¢. 47, in 1961 towards the construction of a building and equipment for same for the production of cheese. ... Section 20(6) (h) creates an artificial restriction on depreciating the full cost of either the building or the equipment as a result of the subsidies by stating that ‘ the capital cost of the property shall be deemed to be the capital cost thereof to the taxpayer minus the amount of the grant, subsidy or other assistance’’. ...

Here there was a ‘‘ Dealer Participation Agreement’’ entered into between Thornerest and Ford so that Thornerest took part in the sales incentive program. ... Because of the conclusion I have reached on the first issue in this appeal, that is, that the amount of $1,384 is properly included in the appellant’s income by virtue of Section 5(1) (a) of the Income Tax Act, it is not necessary for me to consider the alternative submission on behalf of the Minister that the sum of $1,384 should be included in the appellant’s income as a benefit or advantage conferred upon him as a shareholder of Thorncrest within the meaning of Section 8(1) (¢). ...

.’’, ‘‘a six inches drainage pipe below the basement floor level...” plus the requisite surface connection points; and, also, to erect‘ ‘ washroom and toilet facilities in the basement and ground floor level for a total personnel of seventy- five (75) persons together with further facilities on the second floor for a personnel of forty (40) persons, in accordance with the City of Montreal Health Department authorities and the plan hereto annexed’’. ... The appellant’s learned counsel argued that these oft described installations did not constitute an enduring benefit, ‘ they were made’’, contended Mr. ...

:—These are appeals from assessments by the Minister under the Income Tax Act, R.S.C. 1952, ¢. 148, wherein additional tax was levied against the appellant in respect of its 1961 to 1964 taxation years inclusive. ... The amounts of the municipal property taxes assessed and so paid in respect of the demised premises were: for the year 1961 $ 4,217,97 for the year 1962 7,739.65 for the year 1963 10,878.88 for the year 1964 28,743.01 Total $51,579.51 Melforte Limited deducted and remitted to the Minister withholding tax under Section 106(1) (d) of the Income Tax Act at the rate of 15% on the rent of $60,000 per year and $150,000 per year, when applicable, as stipulated under the leases between it and the appellant. ...

Evans & Sons was a member of the unincorporated Board as an active associate member. ... Evans & Sons, left that firm and formed a joint stock company under the name of Carruthers, Evans and Christie Limited to carry on a real estate brokerage business. ...

The appellant submitted that the question of whether the $18,000 was paid for the relinquishment of a franchise was a settled question of fact because in paragraph 3 of the Reply to the Notice of Appeal of the respondent it was admitted ‘‘that the appellant agreed to pay and did pay Seven-Up Vancouver Ltd. the sum of $18,000 in consideration of relinquishing certain territory ’ ’. ...

., continues: “•.. It was argued that the fact that the finance company would return a contract, when requested and repaid, indicates that the appellant had a right to redeem the contracts, but in my view, this fact is consistent with other explanations as to why the finance company would return a contract, and in the absence of evidence of a term of the arrangement giving the appellant a right of redemption, I do not regard it as indicative of such a right.” ... Hill dixit) ”. How then can the appellant, fully paid, and who, understandably so, did not take the trouble of entering in its ledgers ‘‘the amounts receivable from any particular customer’’, lay any claim to the provisions of Section 75B(l)(d). ...

. * =)? ak Q. Now, this whole plan hinged on the obtaining of a first mortgage loan? ...