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In this Court, [1955] S.C.R. 824; [1955] C.T.C. 271, the point was not considered. ...

Angers, J. there considered Section 119 of the Special War Revenue Act, R.S.C. 1927, c. 179 providing: “Everyone liable under this Act to pay to His Majesty any of the taxes hereby imposed, or to collect the same on His Majesty’s behalf, who collects, under colour of this Act, any sum of money in excess of such sum as he is hereby required to pay to His Majesty, shall pay to His Majesty all moneys so collected, and shall in addition be liable to a penalty not exceeding five hundred dollars.” ...

These subsections read as follows: “(6) Such part of the amount that would be the income of a trust or estate for a taxation year if no deduction were made under subsection (4) or under regulations made under paragraph (a) of subsection (1) of section 11 as was payable in the year to a beneficiary or other person beneficially interested therein shall be included in computing the income of the person to whom it so became payable whether or not it was paid to him in that year and shall not be included in computing his income for a subsequent year in which it was paid. (7) For the purposes of subsections (4), (4a) and (6), an amount shall not be considered to have been payable in a taxation year unless it was paid in that year to the person to whom it was payable or he was entitled in that year to enforce payment thereof.’’ ...

He had the facilities he considered to be adequate for his purposes. Neither do I attach particular significance to the circumstance that the appellant had never before engaged in the purchase and sale of real estate. ...

The Association considered that these sums were non-taxable and accordingly omitted to declare them as taxable income in its tax return for the said years. ...

In my view the amount received by the respondent cannot be considered as a compensation in the nature of a retiring allowance. ...

Following the seizure, the claimant’s solicitor, on December 6, 1954, addressed to the Department of Justice a letter (Exhibit B) advising that Joe Zarowney was the owner of the truck, asking that it be released, and requesting that in any event the letter be considered as a claim to the truck on behalf of Joe Zarowney. ...

The purchase and sale by the appellant of Block 350 are entirely different from the purchase and sale of timberlands considered in Anderson Logging Company v. ...

The appellant’s directors considered it proper to record in their accounts the value of the gross royalty interest in such potential production. ...

The meaning of control of, or controlling interests in, corporations has been considered several times by the courts of England and recently by the Supreme Court of Canada in the following cases. ...