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Dally insisted he always considered Ontario as a bare trustee. As far as the second issue in the appeals are concerned, Daily's only evidence was that neither he nor Lucio Sandrin, nor either of the individual appellants, was a trader or speculator but had purchased property in the past for investment purposes only. ...

" It is apparent from the affidavit of Jose Antonio Remedios, filed, that as a senior appeals officer of the Department of National Revenue, he deposed, inter alia (tabs E to O, inclusive, attached to the affidavit), that the Minister considered the objection to the subsection 227.1(1) assessment, reconsidered the assessment and decided to confirm the assessment on the basis that Giovanni Zen was a director at all material times and that other conditions of the section 227 had been met including that of the lack of "due diligence” by the appellants. ...

The respondent’s reason for increasing the aggregate net value of the estate as set out in his decision, following the Notice of Appeal, was as follows: “The Honourable the Minister of National Revenue having duly considered the facts and reasons set forth in the Notice of Appeal and matters thereto relating hereby affirms the said assessment as having been made in accordance with the provisions of the Act and in particular on the ground that the said Walter William Chipman was at the time of his death competent to dispose of property which he was given power to appropriate by the Will of the late Maude M. ...

It must apply, because it is incorporated in the Income War Tax Act by sec. 9(1) thereof which adopts the provisions of the Code with respect to summary convictions, and a general reference to the latter has always, I believe, been considered by our Court as including this sec. 1142. ...

While possibly not identical, there is at least a strong analogy between this tax and customs duties, the effect of which was considered in Attorney-General of- British Columbia v. ...

Further, the Minister ‘s letter contains no enforceable agreement to refund the moneys paid, and, in any event, the Minister could not in this way bind the Crown; whatever be the true implications of that letter they remain as they were when the letter was written; that letter, it seems to me, is something that cannot be considered in this case. ...

In my view par. 1 of the agreement is the primary one to be considered in this connection. ...

It is contended by counsel for Lady Kemp in effect that this money, which Sir Edward obviously considered necessary for the purpose for which it was provided, should be treated as in an air-tight compartment by itself and that the receipt of the amount of this allowance for the maintenance and management of Castle Frank should not increase the burden of income taxes payable by Lady Kemp over and above whatever amount she would have had to pay in any year were this allowance not received by her. ...

For the purposes of these appeals, the provisions of the statutory enactments to be mainly considered are the relevant sections of The Income Tax Acts of 1932 and 1936 (either verbatim, or substantially, the same) and of the Treasury Department Act, 1938, secs. 40, 41 and 42 dealing with appeals in their ascending order from the assessment of the Commissioner of Income Tax to the Board of Revenue Commissioners, to a Judge of the Court of. ...

ARTICLE XXII This Convention and the accompanying protocol which shall be considered to be an integral part of the Convention shall be ratified and the instruments of ratification shall be exchanged at Washington as soon as possible. ...