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Of these two claims, the former ($40,037.50) was waived aside by the Minister and the Appeal Board who, nonetheless, reversed the ministerial disallowance of the latter deduction ($11,095.19) for no other given motive than it ‘‘... was on all fours’’ with appeal No. 319 v. ...

En ce qui regarde le commerce de location de chambres, Trudeau l’exerçait à Montréal, à parts indivises avec un certain René’ Daoust, sous les raisons sociales enregistrées de ‘‘ Alpine Rooms Reg’d”, au numéro 2015, avenue McGill College, puis encore sous celle de ‘‘New Frontenac Hotel and Tavern’’, à 2998 est, rue Rachel. ...

Moreover, the standard printed form of agreement signed by all members of the crew, including the appellant, contained the following provisions: (‘.. in consideration of which services to be duly performed, the said master hereby agrees to pay to the said crew as wages the sums against their names respectively expressed, and to supply them with provisions according to the scale herein.’’ ...

In Phipson on Evidence, 9th edition, page 107, under the title Previous and Subsequent Existence of Facts’’, it is said: "" Continuance, (b) States of mind, persons, or things, at a given time may in some cases be proved by showing their previous or subsequent existence in the same state, there being a probability that certain conditions and relationships continue. ...

The mere existence of some feature which might in such respect make it resemble a bond or debenture is not sufficient to make this preferred share, which is an actual part of the authorized capital of the company, a bond or debenture or anything like it, and thereby transform it into ‘‘ borrowed capital’’ for the purpose of assessment. ...

And Organization Bylaw 14 provided for quotas for delivery as follows: 1 ‘ 14. ... On February 14, 1956, he applied for membership in the appellant and delivered a horse to it for which what was called a ‘‘ Purchase Voucher’’ was handed to him. ... Koehmstedt delivered two horses to the appellant and received a similar ‘‘ Purchase Voucher’’. ...

Brien a témoigné à ce sujet comme suit: ‘ Nous avions acheté tout ce que nous pouvions, tout ce que nous avons pu acheter dans les limites de Ville St-Martin, en bordure du boulevard Labelle, c’est ce qu’il y avait de disponible. ... M.N.R., [1960] S.C.R. 902, à la page 907; [1960] C.T.C. 384, à la page 389 s’appliquent à la présente cause; Je cite: “... ... C.R. 363 à la page 370; [1959] C.T.C. 227 à la page 232, a dit: “... In my view, the utmost that can be said in favour of the appellant’s position is that these lots were acquired generally for the purposes of the partnership business, with an intention to turn them into an income-producing investment if that could be done in the way the partners desired, and otherwise to deal with them in the same way as other lands acquired in the same and other transactions were to be dealt with in the course of the partnership business.” ...

. $ 60,588.32 Nassau therefore deducted the amount of $60,588.32, computed as above, as a terminal loss in computing its income for the fiscal period ending June 28, 1963 and in doing so relied on the provisions of Section 1100(2) of the Regulations. ... DONALD APPLICATORS LTD., GODFREY BUILDING PRODUCTS LIMITED, WHITEMUD BUILDING SUPPLIES LTD, GRAHAM EXCAVATING & EQUIPMENT LTD. SAWYER BUILDING SUPPLIES LTD., McKINNEY PLUMBING & HEATING LTD. CYPRUS BUILDING PRODUCTS LTD., HIGGS CEMENT & MASONRY LTD. ...

Prior to selling the said house, it was appraised by independent appraisers at Hamilton Loan & Investment Company, of Sarnia, Ontario, at an appraised selling price of $20,012. ... It indeed appears clearly that the indemnity paid to the appellant in respect of the capital loss sustained upon the sale of his house when transferred, cannot reasonably be regarded as falling within any of the following categories: (1) ‘ as consideration or partial consideration for accepting the office or entering into the contract of employment’’ as the evidence discloses that it had nothing to do with his engagement as an employee; (ii) ‘as remuneration or partial remuneration for services as officer or under the contract of employment’’ as the evidence discloses that the appellant was receiving under his service contract the full salary appropriate to his appointment. ... Kinder (supra) at p. 692) ‘‘be treated as referable to services or as made to the employee in that capacity ’ ’ if the payment is motivated or caused by reasons of efficiency or even of mere compassion, In this vein, it should not be irrelevant to point out in passing, that if a certain class of taxpayers in this country are required, in order to earn their emoluments of office or of employment, to incur certain expenses, reimbursement of these expenses should not be considered as conferring benefits under Section 5(1) (a) of the Act. ...

Smith, [1927] A.C. 193 at 197; [1917-27] C.T.C. 251: “ Moreover, it is natural that the intention was to tax on the same principle throughout the whole of Canada, rather than to make the existence of taxation depend on the varying and divergent laws of the particular provinces.’’ ... Robins and began to go over a lot of the information he had and as he said, ‘‘ We reviewed our transaction with this Mr. ... Kent & Turcotte, 18 S.C. 486; Fry v. O’Dell, 12 S.C. 263; Irvine v. ...