THE Chief JusTICE (all concur) :—This is an appeal from a judgment of Cattanach, J. pronounced on February 28, 1967, dismissing the appellant’s appeal and allowing the respondent’s cross-appeal from a decision of the Chairman of the Tax Appeal Board and restoring the assessment made by the respondent in respect of the appellant’s 1961 taxation year.
The issue for determination is whether $72,031.65 of the total purchase price of $104,664.04 paid by the appellant to acquire the business of Adolph’s Taxi Co. Ltd. was, as contended by the respondent, for the acquisition of something other than depreciable property or, as contended by the appellant, for either automotive equipment within the meaning of Class 10, Schedule B to the Income Tax Regulations or for a licence for a limited period in respect of property within the meaning of Class 14, Schedule B.
The relevant facts and the submissions of the parties are set out in the reasons of the learned Exchequer Court Judge.
After a consideration of the arguments of counsel and the authorities to which they made reference I find myself so fully in agreement, not only with the conclusion of the learned Exchequer Court Judge but also with his reasons, that I am content simply to adopt them.
I would dismiss the appeal with costs.