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Le Ministre du Revenu national ajoutait aux profits déclarés par l’intimé pour les années 1957, 1958 et 1959, les montants ci-dessous: 1957 — $ 4,230 1958 — $ 6,918 1959 — $20,000 Ces ajoutés aux déclarations du Dr. ... It is extremely difficult to express, but it seems to me that people would say he is addicted to betting, and could not say that his vocation is betting. ’ ’ BETTING ON PERSONAL SKILL. ... Green. ’ ’ ’ PAR TOUS CES MOTIFS, la Cour confirme la décision de la Commission de l’impôt et rejette l’appel, avec allocation des dépens de Cour à l’intimé, après taxation. ...

The deductions were claimed under the United Kingdom Income Tax Act. 1918, Schedule E, Rule 9, which reads: ‘ " 9. ... It must be made for the purpose of earning the profits. ‘ ‘ And in Robert Addie d Sons’ Collieries v. ... Moreover, the words ascertained ’ and ' unascertained ’ appear in a parallel construction, namely, "‘whether ascertained and capable of computation as being..., or unascertained as being... ’’; and both equally relate to what precedes them. ...

This may be illustrated by reference to a life insurance endowment contract where, for example, the face of the policy was $5,000, but at the end of a stated term the payments to be made or credited to the insured under the policy, or to a beneficiary, might, by reason of the accumulation of profits, reach the sum of say $7,000; in that case the payment or credit of the accumulation of profits, $2,000, is not to be treated as " " income, ‘ ‘ at least that is my view in such a case. That illustration would be applicable to life insurance annuity contracts if similar payments or credits were made, or earned, and the words of the section read " " life insurance endowment or annuity contracts.’’ ... We are here concerned only with the true nature of the insurance contract in question and particularly the nature of the payments made thereunder to the appellant; the contract required the insuring company to pay to the appellant a fixed monthly sum if she survived her husband, virtually for the balance of her life, and the question is whether or not that is " " income ‘ from a life insurance annuity contract. ...

See. 10 of €. 14 of 23-24 Geo. V dealing with the application of the various sections of the Act says inter alia: " ‘10. ... In common use, the word " " individual applies to either sex; as the word " " person, ‘ it may mean a woman as well as a man. ... The personal corporation, besides being controlled by an individual who resides in Canada or by such an individual and his wife or any member of his family or by any combination of them, may, according to the definition contained in para. (7) of sec. 2, be controlled by " " any other person or corporation or any combination of them on his or their behalf. ‘ ‘ The word ‘ " person ‘ ‘ for which the word "‘individual’’ has been substituted in other parts of the sentence has been left here, intentionally it may be assumed. ...

Part VIII has the heading ‘‘ Health’’, and Section 1 thereof reads as follows: 1. ... Section 1 of Part VIII of Schedule III contains the words treatment ”, “ mitigation ”, “ prevention ”, “ disease ’ ’ and ‘ ab normal physical state’’. ... So your calorie bank is balanced”; ‘‘ Kat, drink and be merry with Christmas desserts made with Sucaryl’’; “You’re in if you’re thin—you’re out if you’re stout’’; ‘You have 3 months to get in shape for summer’’; ‘‘Let Sucaryl help hold your • calorie-line ’ ”; “ Diet or not—Suearyl helps hold your ‘calorie-line ”; “If you’re a regular sugar user, switch from sugar to Sucaryl and you’ll cut out 100’s of calories per day, without going on a diet’’; ‘‘People with a sweet tooth who have a weight problem, or who just want to keep in shape, are switching to Suearyl’’; ‘‘Suearyl is the product used to sweeten over 90% of the low-calorie food and beverage products sold through your stores”; “If you’re watching your weight—switch to Sucaryl”; “Sucaryl is the easy way to aid your diet efforts’’ “When your diet says ‘no sweets’—switch to Sucaryl’’; ‘ ‘ Sweeten with Sucaryl for low-calorie diets ”; ‘‘Most families have calorie-counters ’ ’. ...

On February 3, 1934, assessment notices for the years 1927 to 1932 inclusive were sent by the Commissioner of Income Tax to Capital Trust Corporation Ltd. including in the income, in addition to the amounts mentioned in the returns, the monthly payments of $500 received by Joseph Merry Mackenzie during the said years, to wit: for the year 1927 $24,416.67 plus interest ‘ ‘ ‘ ‘ ‘ ‘ 1928 6,000.00 " (66 1929 6,000.00 “ 66 6 1930 6,000.00 " " 1931 6,000.00 6 6 1932 3,290.00 On or about February 21, 1934, within one month after the date of mailing of the notice of assessment, the Estate of Joseph Merry Mackenzie, through its solicitors, served a notice of appeal upon the Minister, in accordance with the requirements of sec. 58 of the Income War Tax Act. ... The decision in fact appears to have been addressed to Capital Trust Corporation Ltd. and to Coffey & McDermott, its solicitors. ... Relief may be obtained in England in regard to surtax in certain circumstances under sec. 34 of the Finance Act, 1927 (17 & 18 Geo. ...

And in the second column you have items under " Taxable income ‘; what are those figures? ... The effect was that when he became liquidator there was that much less available for distribution to the shareholders because they had already received that. ‘ ‘ Q. ... In this case the capital recovery would amount to $143,369.21, as follows: Amount distributed in 1930_. $ 17,946.64 " " ‘ ‘ 1931 18,000.00 "" ‘ ‘ " 1932 12,000.00 Amounts distributed by the liquidator ($75,000 and $1,500) 76,500.00 Accounts receivable and money assigned to Royal Trust Co. 18,922.57 $143,369.21 If we deduct the amount assigned to the Royal Trust Co., namely, $18,922.57, for accounts receivable and cash on hand, we are left with a balance of $124,446.64. ...

The appellant’s income tax returns show that the structure — as opposed to the contents — cost a total amount of $10,767.73. ... In due course, the tax assessors sought further information from the appellant with a view to a “ recapture ’ ’ assessment. ... It is now contended in this Court that the capital cost of the hotel — as opposed to the contents — was over $16,000. ...

" ‘2. He was in receipt of. a net income during 1926. of $24,914.50. “*3. ... The income of the wife of William Kennedy, Jr., for the year 1926, was $1,720 made up as follows: Dominion Government Annuity $1,500 Industrial bond interest- 220 " " 8. ... " " Approved and agreed to. ‘ ’ The contention that the wife’s annuity contract issued under the provisions of 7-8 Edward VII, €. 5, was issued free from taxation, may be first considered. ...

The claim for the tax is made under Section 86 of the Excise Tax Act, formerly the Special War Revenue Act, R.S.C. 1927, ¢. 179. ... Planters Nut & Chocolate Co. Ltd., [1952] Ex. C.R. 91 at 92; [1951] C.T.C. 366. ... Webster’s New International Dictionary, Second Edition, defines ‘ ‘ implement ’ ’ as follows: “1. ...