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The authorized capital was increased by 100,000 preference ‘ ‘A” shares of $1 each and each of the children who had now become of age, received preference “A” shares for the transfer of the assets respectively made by them. ... Jones, [1930] A.C. 415 at 423: “... The fact that a man does not mean to hold an investment may be an item of evidence tending to show whether he is carrying on a trade or concern in the nature of trade in respect of his investments, but per se it leads to no conclusion whatever. ’ ’ And then Lord Carmont stated, at page 392: “I do not wish, however, to read this passage out of its context and without regard to the facts then under consideration, and I draw attention to Lord Dunedin’s language being used with reference to ‘an investment’, meaning thereby, as I think, the purchase of something normally used to produce an annual return on such lands, houses, or stocks and shares. ...

Even if the ‘ ‘... transaction... (had been) an isolated one... (however) this would not necessarily) exclude it from the category of trading or business transactions of such a nature as to attract income tax to the profit therefrom.’’t [2] (words in brackets are mine). ... Clara Fish who had died on March 9, 1953 — that is to say, some time before the sale of the property by Salmon on September 22, 1953, so the amount was now due to Mrs. ... C.R. 622 at 631; [1948] C.T.C. 326 at 334; affirmed, [1949] S.C.R. 706; [1949] C.T.C. 196. 3 * Article 180 of Notarial Code; Cardinal v. ...

McDonald, a senior partner of Price, Waterhouse & Company, and Mr. ... Richardson, a senior partner of Clarkson, Gordon & Company. Mr. McLellan gave a detailed description of how the accounts of the appellant’s producing department were kept. ... Only one other subject remains for consideration, namely, whether the Minister, in determining the base for the computation of the appellant’s deductible allowance, had any right to deduct the sum of $8,642,196.84, which is described in Exhibit 76 as ‘‘ Increase (decrease) in unrealized profit in Supply, Manufacturing and Marketing inventories’’. ...

Gault did, essentially, subscribe and agree to anything, beyond an undertaking to collect, during a triennial period, March 21, 1960, to March 20, 1963, the commissions " issued or renewed for any clients of the late Herbert J. ...

It may, I think, be assumed from the use of the word “ interest’’ in Section 20 to describe the allowance thereby permitted, as well as from the nature of the situation in which the allowance may be made, that the purpose of such allowance is to compensate the payer for the loss of the opportunity he would otherwise have of using the money pending arrival of the time for payment of the duties. ...

C.R. 77; [1947] C.T.C. 63, to consider the time when deductions could be made within the exception of Section 6(a) of the Income War Tax Act, R.S.C. 1927, c. 97, which reads: * *6. ...

& C. 217. But I can see no warrant whatever, even where the matter arises in the Province of Quebec, for invoking Article 1163 of the Code of Civil Procedure, upon which counsel for Mr. ...

The appeal raises the question of the liability of the appellant to pay Canadian income tax in respect of income derived by him as a partner from activities carried on in the United States by certain partnerships organized in the United States, in view of the provisions of the Convention and Protocol between Canada and the United States for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion in the Case of Income Taxes and of The Canada-United States of America Tax Convention Act, 1943, S. of C. 1943-4, c. 20 (as amended by $. of C. 1950, c. 27), by which the Convention and Protocol were approved and declared to have the force of law in Canada and to prevail over any other law to the extent of any inconsistency therewith. ...

This regulation provides for a depletion allowance of 3314 % of ‘‘the aggregate of... profits for the taxation year reasonably attributable to the production of... industrial minerals... minus the aggregate amount of deduction provided by...’’ ...

By his Notice of Assessment dated January 10, 1952, the appellant disallowed the payment of $4,000.00 as ‘‘ Alimony Disallowed, $4,000.00” and endorsed on the back of the said notice were the words “Lump Sum Payments of alimony not an allowable Expense’’. ...