Thurlow, J (per curiam) (judgment delivered from the Bench):—We have decided not to hear you Mr Chalmers and Mr Storrow.
It is unnecessary to review the evidence as it is fully set out in the reasons of the learned trial judge.
In our view there is nothing in the evidence which would serve to characterize the purchase by the appellant of the highly speculative property referred to as the “Stonehouse farm” at a price far in excess of its value for agricultural purposes as other than a speculation in land with a view to realizing profit from it in any way that might become expedient, including sale, or which would lead to the conclusion that the purchase of the property and the sales here in question were anything but transactions in the course of the appellant’s business of dealing in land. The profits realized on such sales are accordingly income from the appellant’s business and the appellant is liable for income tax in respect of them.
The appeal will be dismissed with costs.