An estate received a portion of its income as dividends from a Canadian mining company and paid a portion of its income to the taxpayer, who had a life interest in the property held by the executors. In finding that she was entitled to claim a depletion allowance in respect of her pro rata portion of the dividends received by her (based on s. 5(1)(a), which provided a deduction for “income derived from mining”), Cameron DJ stated (at p.