34 TRANSACriONS OK ROYAL SCOTTISH ARIiOKICULTURAL SOCIETY, 



as a separate estate for the purposes of assessment. It gives 

 him the option of applying Schedule B of the Income Tax to 

 one part of his estate and Schedule D of the Income Tax to 

 another part of the estate. It is, of course, a very valuable 

 concession that is given, not primarily as a relief to the tax- 

 payer, but in order to encourage afforestation. . . . What we 

 intend by Subsection (3) is to give the owner of woodlands 

 precisely the same advantage which is given to the trader. 

 Supposing a landlord spends money upon developing woodlands 

 and that money is all lost, and does not give him any advantage, 

 iie may treat it as a loss, just as the trader would treat it as 

 a loss. ... It does not bring him the appropriate advantage. 

 He spends money on his woodlands and expects to get a 

 return. He does not, and he will treat that expenditure as a 

 loss just as a trader would. The other descriptions of loss 

 which the hon. gentleman has mentioned would be treated 

 as a loss without this clause. They would be loss in any 

 event. ..." 



Section 23 of the Customs and Inland Revenue Act, 1890, 

 referred to above, is as follows : — 



"(i) Where any person shall sustain a loss in any trade, 

 manufacture, adventure or concern or profession, 

 employment, or vocation carried on by him either 

 solely or in partnership, or in the occupation of lands 

 for the purpose of husbandry only, it shall be lawful 

 for him, upon giving notice in writing, to the Surveyor 

 of Taxes for the district, within six months after the 

 year of assessment, to apply to the Commissioners for 

 the general purpose of the Acts relating to Income 

 Tax for an adjustment of his liability by reference to 

 the loss and to the aggregate amount of his income 

 for that year, estimated according to the several rules 

 and directions of the said Acts. 

 "(2) The said Commissioners shall, on proof to their satisfaction 

 of the amount of the loss and of the payment of Income 

 Tax upon the aggregate amount of income, give a 

 certificate authorising repayment of so much of the 

 sum paid for Income Tax as would represent the tax 

 upon income equal to the amount of loss, and such 

 certificate may extend to give exemption or relief by 

 way of abatement in accordance with the provisions 



