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DeMara & Co. Limited as real estate agent on an established scale of fees. ... This conclusion has been reached after giving careful consideration to the proposal. ’ ’ To this the syndicate answered on February 18: “We are sorry to hear of the view expressed by your Corporation. ... He said ‘ Here is some land we can get at X dollars and a few days or months or years from now it is going to be worth a lot more money’? ...

Fields & Co. [1948] O.R. 120 at 129, and the cases therein cited. ... In Liberty & Co. Ltd. v. C.I.R. 12 T.C. 630, a somewhat similar case arose. ... At page 672-3 he said: " " Does an issue of redeemable shares in a transaction of this kind incorporate the undistributed income of the vendor company? ...

Cameron was what colloquially was referred to at the time as a ‘‘dividend stripper ’ \ The questions and answers were as follows: Q. ... Cameron’s group needed — that it was to be as it was put in the evidence — a “daylight loan’’. ... December 24, 1961 — Sunday. December 25,1961 — Christmas. December 26,1961 — Boxing Day.) ...

For that reason, " " building” is not a genus, nor can the words "‘or other structure” be regarded as general words in Class 3. ... London County Council (1899), 81 L.T. 450, and Regent’s Canal & Dock Co. v. ... That case should not be followed for two reasons: 1. that construction would appear to reduce 66 structure” to the equivalent of building and therefore make " " structure ‘ ‘ or the words, "‘other structure’’, entirely superfluous. ...

Especially with the hope of reducing overlapping costs, appellant and Oxford Motors, on October 1, 1951, formed a partnership under the firm name and style of ‘‘British Car Centre’’, thereafter carrying on their businesses jointly, each associate ‘‘being entitled to one-half of the profits and liable for one-half of the losses (cf. exhibit 4, s. 6) ”. ... I would quote paras. 1 (partially) and 4(a) which read: £ “ (1) The debt was originally 249,310 We agree to cancel our Invoice for Special Charges 1,668 247,642 And to grant you a 15% Allowance on the balance of £247,642 37,146 Leaving a balance of 210,496 (4) The foregoing offers are made on the understanding that: (a) The 15% Allowance of £37,146 and the Credit of £1,688 referred to at (1) will not remain as a debt after the payment by you of the balance of £123,666 on the dates indicated above.” ... Davie & Sons, a dry dock owner and ship builder, upon completion of certain contracts owed $914,000 to Canadian Commercial Corporation, a Crown company. ...

It admittedly is a Canadian firm with its head office in Toronto, carrying on the business of selling, leasing and servicing Caterpillar ’ ’ heavy construction machinery in the province of Ontario. ... However, it so happened that the afore-mentioned Gulfstream plane, according to paragraph 5 of the agreed statement, ‘‘ could not, on delivery pursuant to the purchase contracts’’ (exhibits 1 and 2) ‘‘be used for the transportation of Crothers’ executives or customers. ... The pertinent statutory legislation assented to by the parties, Section 30(1) (a) of the Excise Tax Act (R.S.C. 1952, ¢. 100) enact as follows: 30. (1) There shall be imposed, levied and collected a consumption or sales tax of eight per cent (plus a three per cent Old Age Security tax) on the sale price of all goods (a) produced or manufactured in Canada. ...

Fab: — — $1,019.47 $1,002.98 The assessment of $18,618.45 included a disposal in 1951 by the appellant of part of lot 5 to Les Produits de Ciment de Sherbrooke Ltée, which he owned and controlled, but the deed to the property was not executed until 1955. ... When the appellant was called, he testified that at all material time he owned a controlling interest in a cement company known as Les Produits de Ciment de Sherbrooke Ltée and that he also owned about a one-third interest in Fabi & Fils Limitée, of which he was vice-president and general manager and which carried on a general contracting business, including the building of roads, in the city of Sherbrooke, province of Quebec. ... See Statutes of Quebec, s. 1415, ¢. 75, Geo. VI, 1950, sanctioned March 14, 1951. ...

This claim is put forward under Section 5(p) of the Income War Tax Act, R.S.C. 1927, chapter 97, as amended by Section 4(5) of chapter 43 of the Statutes of 1944-1945, assented to on August 15, 1944, which reads in part as follows: “5. 4 Income’ as hereinbefore defined shall for the purposes of this Act be subject to the following exemptions and deductions: (p) amounts in respect of losses sustained in the three years immediately preceding and the year immediately following the taxation year,.... ” The appeal turns on the meaning of the word ‘‘year’’ in the expression ‘‘the year immediately following the taxation year’’. ... City of Montreal (1885), 12 S.C.R. 384 at 386, where he said: “ I am quite willing to admit that the intention to exempt must be expressed in clear unambiguous language; that taxation is the rule and exemption the exception, and therefore to be strictly construed; ’ ’ Then I put the rule of construction of an exempting provision of the Income War Tax Act as follows: ‘‘ Just as receipts of money in the hands of a taxpayer are not taxable income unless the Income War Tax Act has clearly made them such, so also, in respect of what would otherwise be taxable income in his hands a taxpayer cannot succeed in claiming an exemption from income tax unless his claim comes clearly within the provisions of some exempting section of the Income War Tax Act: he must show that every constituent element necessary to the exemption is present in his case and that every condition required by the exempting section has been complied with.” ...

The appellant is not a ¢ component company” as defined in sec. 4A(4). ... But that is quite a different thing from * acquiring its business as a going concern after January 1, 1938”. ... And by "‘direct’’ is meant, I think, " " direct the Board of Referees’’, appointed under sec. 13 of the Act. ...

In this connection, the appellant used the word 11 attitude 7 ’, which, in my opinion, aptly described his state of mind. ... No question arises as to when the Minister made an original assessment but by notice of re-assessment dated June 20, 1958, the Minister added to the said declared income the following amounts (see Ex. 8): 4 Taxable Income previously reported $ 9,425.00 Add profit on sale of oil leases and permits, Northwest Territories Per mits —-.. $11,500.00 B.C. ... The Northwest Territories Permits were subsequently allowed to lapse and the Taxpayer’s remaining one quarter interest in them was lost. ’ ’ As to the amount of $5,273.60 assessed by the Minister in respect of the B.C. permits Nos. 250 and 251, the appellant’s submission was as follows: “(B) British CoLUMBIA PERMITS Nos. 250 AND 251. ...