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On these facts and submissions I am of the opinion following: In the consideration of this matter, the applicable sections of the Income Tax Act, R.S.C. 1952, c. 148, in the determination of this appeal are Sections 38, 4 and 139(1) (e) which read as follows: 41 3. ...

Early in 1955 he gave instructions which resulted in the incorporation of United Glass & China Imports Ltd. by Manitoba Letters Patent, dated March 22, 1955, with the following objects: “To enter upon and undertake the importing and exporting of goods, wares and merchandise of every kind, character and description, to buy and sell such goods, and to do a general import and export business; To carry on a general mercantile business as importers and dealers in all kinds of goods, wares and merchandise, whether wholesale or retail, and by means of stores, warehouses, shops or agencies in all such places as the company may deem to be profitable and advantageous; To act as commission or commercial agents in respect of all kinds of natural imported or manufactured products of every nature and description, and to buy and sell all such products upon a commission, salary or other lawful consideration; To act as agents, commission agents, commission merchants, brokers or representatives in Canada and any foreign country or countries for Canadian or foreign commercial houses and for other persons, firms or corporation.”’ ...

After a lengthy consideration of the evidence and bearing in mind that the appellant was a novice in these matters at the time, I have come to the conclusion that his explanation is sufficiently plausible to support his evidence that he did not intentionally misrepresent his income by not accounting for the sales which the Minister has added. ...

The considerations prompting the transaction may be of such a business nature as to invest it with the character of an adventure in the nature of trade even without any intention of making a profit on the sale of the purchased commodity.” ...

It is essential to a proper appreciation of the issue in the appeal, which is a narrow one, that the relevant facts be assessed correctly and this involves consideration of events prior to the organization of the appellant as well as those happening subsequently. ...

After lengthy consideration of the facts I am of the opinion that the discounts realized in the years 1949 to 1954 were not profits from a business within the meaning of that term as defined in the applicable statutes. ...

That leaves for consideration the part of the expenses in issue that would have been deductible for one of the three years in question, if it had not been for the exemption conferred by subsection (5) of Section 83, under either one of two heads, that is (a) as being current expenses of operating the exempt mine, (b) by virtue of subsection (3) of section 83A as being exploration or development expenses incurred in searching for minerals, because they were at one and the same time incurred for both purposes. ...

L’appelant a cotisé comme revenus imposables les revenus provenant des opérations de l’intimée pour les trois années sous considération, sur la base de 3% de son capital employé. ...

The eldest son of the testator entered on the lands as heir at law and sold the lands to a purchaser for a valuable consideration. ...

We were informed by the Solicitor- General that these amounts are regarded, not as income but as capital sums which the company bears in consideration of the risk attaching to the investment which is borne by the investor. ...