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A votre connaissance personnelle, il y a eu une autre considération que celle indiquée au contrat que vous avez recu? ...

Even permanency of abode is not essential since a person may be a resident though travelling continuously and in such a ease the status may be acquired by a consideration of the connection by reason of birth, marriage or previous long association with one place. ...

., says: “While the appellant’s submission appears attractive at first sight and merits consideration I am of the opinion that it is unsound and must be rejected. ...

The Special Commissioners held that: ‘(On consideration of the particular facts of this case and the evidence before us, having in mind especially the number of purchase transactions over a period of about 18 months, together with the manner in which the policies were selected and purchased in pursuance of an organised scheme, we hold that the appellant engaged in a concern in the nature of trade, resulting in profits—the fruit of the capital laid out—which are assessable to income tax under Case 1 of Schedule D.” ...

However upon subsequent consideration I do not think the facts are actually analogous, nor do I believe that the decision of Mr. ...

After having given careful consideration to all the evidence, I am not satisfied that there is a balance of probability that the appellants acquired this land for the purpose of operating a feed lot to the exclusion of any disposition of it at a profit. ...

As I understand it the principle upon which the beneficial ownership of property held jointly by two or more persons is determined, where the property has been contributed by one of them alone, is that while at law the title is vested in the joint holders, if valuable consideration has not been given therefor by the other or others, they, in equity, hold on a resulting trust for the contributor of the property, except in cases in which the contributor intended to make a gift of some interest in the property to the other joint holder or holders. ...

A first reading of subsections (9) and (10) of Section 50 of the Excise Tax Act conveys the impression that this is somewhat uncommon and drastic legislation, but such impression is not borne out by a more mature consideration of the legislation. ...

Counsel for the appellant contended that the payment of $1,903.80 now in question, although prompted by the employeremployee relationship which had subsisted between the appellant and the legal firm until its abrupt termination on September 11, 1961, was a gift or benefaction of an exceptional kind, personal to the appellant and motivated by altruistic considerations of the former employer for the appellant’s wife and family. ...

I would infer moreover that one of the more important considerations which he had in mind in deciding to buy the property was that he might obtain a deduction for capital cost allowance which would not represent an actual outlay of money, but would, because of his large income from his practice and the rate of taxation applicable thereto, afford a saving in income tax of about half the amount of such allowance. ...