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On the considerations to which I have adverted above, there will be judgment allowing the appeal in respect of the salary of the Local Judge in Admiralty for the year 1920, declaring it free from income tax. ...

A good deal can be said in favour of the proposition that the sale price is what the purchaser pays to the vendor as consideration for the object of the sale and that, since the purchaser has to pay and does pay the excise tax included in the sale price, such excise tax must be considered, for the purpose of calculating the sales tax, as forming part of the purchase price. ...

I must say that, after giving the matter careful consideration, I feel unable to adopt this view. ...

After giving a most anxious consideration to the construction of s. 11, ss. (2), I am unable to reach any other conclusion than that the income in question is taxable. ...

This company was granted exactly the same corporate powers as the other two companies and Interprovincial transferred to it all its holdings of United States securities, the consideration to Interprovincial being all the capital stock issued by North American. ...

Fisher; and that an intending purchaser (after giving consideration to all the factors involved, such as the uncertainty of the period during which the income would be paid, the possibility of depreciation in value of the leasehold property, the possible failure of the lessee thereof, or of the lease being surrendered and the consequent necessity of having to convert the realty into a self-contained store, and the incidence of income tax) would not pay more than $55,000 for the asset as a whole, and that that sum—alleged to be the fair market value of the assets—should be the valuation established by the respondent. ...

Since the decision in the Imperial Oil Limited case, supra, I have given further consideration to the statement or implication in that case, and in several others, that section 6(a) inferentially permits the deductibility of the disbursements and expenses that fall outside its exclusions, and am now of the opinion that such a statement or implication is, strictly speaking, not correct. ...

The Shorter Oxford English Dictionary (Third Edition) defines "‘to superannuate’’ as ‘‘to dismiss or discharge from office on account of age; esp. to cause to retire from service on a pension; to pension off”; and ""pension” is defined as ‘‘an annuity or other periodical payment made, esp. by a government, a company, or an employer of labour, in consideration of past services or of the relinquishment of rights, claims, or emoluments.” ...

My opinion is arrived at partly by the definition of “investment income’’, but in the main by a somewhat lengthy consideration of the history of the legislation in regard thereto since the surtax thereon was first levied. ...

., makes it plain that questions of this nature must be decided upon the facts of the particular case under consideration. ...