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While the multiplicity of transactions does not of itself determine that they were operations in a scheme of profit-making, it has been held that it may be an important factor when considered in the light of the surrounding circumstances. I am not persuaded that, so considered, the transactions entered into by the respective appellants were not numerous. ... The mortgages were not the kind that would be considered for investment purposes by a person who was primarily concerned with a return of his money by way of interest. ...

I do not think that the patrons of the beer licensees, who expect to be treated, could be seriously considered as an advertising or sales promotion medium, and one might safely say that no brewer’s business could long survive on any patronage derived from those who look to be served with free beer. ... It is difficult to understand why it is considered necessary for brewers to make gifts of beer to the patrons of beer licensees, and one cannot but wonder why they do not agree among themselves to refrain from the practice. ... I am inclined also to think that the expenditures made by the appellant cannot be considered a necessary business expense because of the provisions of the Government Liquor Control Act of Manitoba, if indeed they are not expressly or impliedly forbidden by that Act, the sale of beer is so controlled and regulated that expenditures for treating would seem altogether unnecessary because everybody concerned with the trade is exactly upon the same footing; everything in the nature of advertising is severely limited, and no doubt that was deliberately done as a matter of public policy, in connection with this particular trade. ...

For the reasons stated in the Spruce Falls case (which need not be repeated here but may be considered as part of my reasons for judgment in this case), I hold that the appellant is entitled to the benefit of the provisions of para. ... It may well be as suggested by counsel for the appellant that logs when “barked” are still logs: but in view of the limitations mentioned, I think that item of cost should be excluded entirely from the computation, “barking” being considered as part of the manufacturing:or processing. ... I considered that submission in the Spruce Falls case and for the reasons given in that case I must reject it. ...

From the evidence it is beyond doubt that there are two distinct relationships in law to be considered in this matter: firstly, there is the relationship between the appellant and Cuddy Turkey Farms Limited which was that of debtor and creditor in respect of turkey inventory of the appellant in the sum of $24,222.11; and secondly, there is the relationship between the appellant and Maple Leaf Mills Limited which was that of lender and borrower in respect of a similar sum of $24,222.11. ...

The appellant, for taxation year 1959, assessed this repayment of $13,844.20 as ‘‘income of the estate’’, accruing at the time it was paid, whilst the respondent’s contention is that it should be considered as income due to the deceased personally. ...

I have considered very carefully the reasons for judgment of Mr. Monet and I am in complete accord with his conclusions of fact and law; I feel that I can add nothing of value to what he has said. ...

For the reasons given in that case, and which are to be considered as forming part of this judgment, the appeal herein will be allowed, the decision of the Income Tax Appeal Board set aside, and the assessment made upon the respondent by the Minister will be affirmed. ...

For the reasons given in that case, and which are to be considered as forming part of this judgment, the appeal herein will be allowed, the decision of the Income Tax Appeal Board set aside, and the assessment made upon the respondent by the Minister will be affirmed. ...

For the reasons given in that case, and which are to be considered as forming part of this judgment, the appeal herein will be allowed, the decision of the Income Tax Appeal Board set aside, and the assessment made upon the respondent by the Minister will be affirmed. ...

For the reasons given in that case, and which are to be considered as forming part of this judgment, the appeal herein will be allowed, the decision of the Income Tax Appeal Board set aside, and the assessment made upon the respondent by the Minister will be affirmed. ...