Guy
Tremblay:—This
case
was
heard
at
Quebec
City
on
January
22,
1976.
1.
Summary
These
are
the
appeals
of
three
companies,
J-Euclide
Perron
Ltée,
Mars
Finance
Inc
and
Les
Immeubles
Perron
Ltée,
all
of
Chicoutimi,
Quebec,
in
respect
of
the
1971,
1972
and
1973
taxation
years.
The
respondent
considered
them
to
be
associated
and
taxed
them
accordingly.
A
single
judgment
is
rendered
for
all
three
appellant
companies,
since
the
evidence
was
given
at
the
same
time
and
the
amounts
of
tax
involved
have
been
admitted.
2.
Burden
of
Proof
The
appellants
have
the
burden
of
showing
that
the
respondent’s
assessments
are
Incorrect.
This
burden
of
proof
follows
not
from
any
particular
section
of
the
Income
Tax
Act
but
from
a
decision
of
the
Supreme
Court
of
Canada
in
R
W
S
Johnston
v
MNR,
[1948]
CTC
195
at
202;
3
DTC
1182:
Every
such
fact
found
or
assumed
by
the
assessor
or
the
Minister
must
then
be
accepted
as
it
was
dealt
with
by
these
persons
unless
questioned
by
the
appellant.
3.
Facts
3.1
According
to
the
evidence
adduced,
the
companies
mentioned
below
were,
as
of
December
31,
1971,
owned
by
the
following
persons:
(a)
J-Euclide
Perron
Lté:
|
Fernand
Perron
|
33%%
|
|
Georges-Henri
Perron
|
3313%
|
|
André
Perron
|
33%%
|
These
three
persons
are
brothers.
(b)
Les
Placements
du
Moulin
Ltée:
|
Fernand
Perron
|
|
33%%
|
|
|
Georges-Henri
Perron
|
|
3313%
|
|
|
André
Perron
|
|
3313%
|
|
|
(c)
Les
Immeubles
Perron
Ltée:
|
|
|
Mrs
J-Euclide
Perron
(mother)
|
|
2%
|
|
Madeleine
Perron
|
\
|
These
five
persons
are
the
|
|
|
Colette
Perron
|
I
daughters
of
Mrs
J-Euclide
|
|
|
Monique
Perron
>
Perron
and
the
sisters
|
49%
|
|
Michèle
Perron
|
(
of
Fernand,
Georges-Henri
|
|
|
Thérèse
Perron
|
/
|
and
André
Perron.
|
|
|
Les
Placements
du
Moulin
Ltée
|
|
49%
|
|
100%
|
|
(d)
Mars
Finance
Inc:
|
|
|
The
three
Perron
brothers
|
16.21%
|
|
Georges-Henri
Perron’s
children
|
0.33%
|
|
The
five
Perron
sisters
|
|
3.04%
|
|
J-Euclide
Perron
Ltée
|
|
20.21%
|
|
Les
Placements
du
Moulin
Ltée
|
1.76%
|
|
Les
Immeubles
Perron
Ltée
|
10.32%
|
|
Outsiders
|
|
48.13%
|
|
100
|
%
|
3.2
In
1972
and
1973
the
percentages
shown
above
did
not
vary
enough
to
affect
the
principle
involved,
so
that
the
above
figures
serve
as
a
basis
for
ruling
on
the
assessments
for
1972
and
1973
also.
3.3
For
1971
each
appellant
company
is
applying
to
have
the
first
$35,000
of
income
taxed
at
a
rate
of
18%
instead
of
51%:
for
1972
and
1973
they
are
seeking
to
have
the
first
$50,000
of
income
taxed
at
25%
instead
of
50%
(1972)
and
49%
(1973),
the
whole
in
accordance
with
subsection
39(2)
of
the
Act
(RSC
1952,
c
148
as
amended)
and
section
125
of
the
Act
(SC
1970-71-72,
c
63
as
amended).
4.
Point
at
Issue
The
issue
is
whether
the
three
appellant
companies
are
associated
within
the
meaning
of
the
Acts
concerned.
A
reply
in
the
negative
would
authorize
the
appellant
companies
to
take
advantage
of
the
benefits
explained
above.
5.
Sections
of
the
Act
5.1
1971
The
following
provisions
of
the
Act
(RSC
1952,
c
148
as
amended)
apply
to
1971:
39.
(4)
For
the
purpose
of
this
section,
one
corporation
is
associated
with
another
in
a
taxation
year,
if,
at
any
time
in
the
year,
(a)
one
of
the
corporations
controlled
the
other,
(b)
both
of
the
corporations
were
controlled
by
the
same
person
or
group
of
persons,
(c)
each
of
the
corporations
was
controlled
by
one
person
and
the
person
who
controlled
one
of
the
corporations
was
related
to
the
person
who
controlled
the
other,
and
one
of
those
persons
owned
directly
or
indirectly
one
or
more
shares
of
the
capital
stock
of
each
of
the
corporations,
(d)
one
of
the
corporations
was
controlled
by
one
person
and
that
person
was
related
to
each
member
of
a
group
of
persons
that
controlled
the
other
corporation,
and
one
of
those
persons
owned
directly
or
indirectly
one
or
more
shares
of
the
capital
stock
of
each
of
the
corporations,
or
(e)
each
of
the
corporations
was
controlled
by
a
related
group
and
each
of
the
members
of
one
of
the
related
groups
was
related
to
all
of
the
members
of
the
other
related
group,
and
one
of
the
members
of
one
of
the
related
groups
owned
directly
or
indirectly
one
or
more
shares
of
the
capital
stock
of
each
of
the
corporations.
(4a)
For
the
purpose
of
this
section,
(a)
one
person
is
related
to
another
person
if
they
are
“related
persons’*
or
persons
related
to
each
other
within
the
meaning
of
subsection
(5a)
of
section
139;
(b)
“related
group”
has
the
meaning
given
that
expression
in
subsection
(So)
of
section
139;
and
(c)
subsection
(5d)
of
section
139
is
applicable
mutatis
mutandis.
(5)
When
two
corporations
are
associated,
or
are
deemed
by
this
subsection
to
be
associated,
with
the
same
corporation
at
the
same
time,
they
shall,
for
the
purpose
of
this
section,
be
deemed
to
be
associated
with
each
other.
139.
(5)
For
the
purposes
of
this
Act,
(a)
related
persons
shall
be
deemed
not
to
deal
with
each
other
at
arm’s
length;
and
(b)
it
is
a
question
of
fact
whether
persons
not
related
to
each
other
were
at
a
particular
time
dealing
with
each
other
at
arm’s
length.
(5a)
For
the
purpose
of
subsection
(5),
(5c)
and
this
subsection,
“related
persons”,
or
persons
related
to
each
other,
are
(a)
individuals
connected
by
blood
relationship,
marriage
or
adoption;
(b)
a
corporation
and
(i)
a
person
who
controls
the
corporation,
if
it
is
controlled
by
one
person,
(ii)
a
person
who
is
a
member
of
a
related
group
that
controls
the
corporation,
or
(iii)
any
person
related
to
a
person
described
by
subparagraph
(i)
or
(il);
(c)
any
two
corporations
(i)
if
they
are
controlled
by
the
same
person
or
group
of
persons,
(ii)
if
each
of
the
corporations
is
controlled
by
one
person
and
the
person
who
controls
one
of
the
corporations
is
related
to
the
person
who
controls
the
other
corporation,
(iii)
if
one
of
the
corporations
is
controlled
by
one
person
and
that
person
is
related
to
any
member
of
a
related
group
that
controls
the
other
corporation,
(iv)
if
one
of
the
corporations
is
controlled
by
one
person
and
that
person
is
related
to
each
member
of
an
unrelated
group
that
controls
the
other
corporation,
(v)
if
any
member
of
a
related
group
that
controls
one
of
the
corporations
is
related
to
each
member
of
an
unrelated
group
that
controls
the
other
corporation,
or,
(vi)
if
each
member
of
an
unrelated
group
that
controls
one
of
the
corporations
is
related
to
at
least
one
member
of
an
unrelated
group
that
controls
the
other
corporation.
(5b)
Where
two
corporations
are
related
to
the
same
corporation
within
the
meaning
of
subsection
(5a),
they
shall,
for
the
purpose
of
subsection
(5)
or
(5a),
be
deemed
to
be
related
to
each
other.
(50)
In
subsection
(5a),
(5d)
and
this
subsection,
(a)
“related
group”
means
a
group
of
persons
each
member
of
which
is
related
to
every
other
member
of
the
group;
and
(b)
“unrelated
group”
means
a
group
of
persons
that
is
not
a
related
group.
(5d)
For
the
purpose
of
subsection
(5a)
(a)
where
a
related
group
is
in
a
position
to
control
a
corporation,
it
shall
be
deemed
to
be
a
related
group
that
controls
the
corporation
whether
or
not
it
is
part
of
a
larger
group
by
whom
the
corporation
is
in
fact
controlled;
(b)
a
person
who
had
a
right
under
a
contract,
in
equity
or
otherwise,
either
immediately
or
in
the
future
and
either
absolutely
or
contingently,
to,
or
to
acquire,
shares
in
a
corporation,
or
to
control
the
voting
rights
of
shares
In
a
corporation,
shall,
except
where
the
contract
provided
that
the
right
is
not
exercisable
until
the
death
of
an
individual
designated
therein,
be
deemed
to
have
had
the
same
position
in
relation
to
the
control
of
the
corporation
as
if
he
owned
the
shares;
and
(c)
where
a
person
owns
shares
in
two
or
more
corporations,
he
shall
as
shareholder
of
one
of
the
corporations
be
deemed
to
be
related
to
himself
as
shareholder
of
each
of
the
other
corporations.
5.2
1972
and
1973
The
following
provisions
of
the
Act
(SC
1970-71-72,
c
63
as
amended)
apply
to
1972
and
1973:
subsections
251(1),
(2),
(3),
(4),
(4a),
(4b),
(5)
and
(6)
and
are
similar
to
the
above-mentioned
subsections
39(4a)
and
139(5),
(5a),
(Sc)
and
(5d).
Subsections
256(1)
and
(2)
are
similar
to
subsections
39(4)
and
(5),
except
that
the
ownership
of
shares
required
in
paragraphs
39(4)(c),
(d)
and
(e)
is
replaced
with
ownership
of
at
least
10%
of
the
issued
shares,
as
provided
by
paragraphs
256(1)(c),
(d)
and
(e).
Paragraph
256(1)(e)
reads
as
follows:
256.
(1)
For
the
purposes
of
this
Act
one
corporation
is
associated
with
(e)
each
of
the
corporations
was
controlled
by
a
related
group
and
each
of
the
members
of
one
of
the
related
groups
was
related
to
all
of
the
members
of
the
other
related
group,
and
either
of
the
related
groups
owned
directiy
or
indirectly,
in
respect
of
each
corporation,
not
less
than
10%
of
the
issued
shares
of
any
class
of
the
capital
stock
thereof.
5.3
Paragraph
39(4)(e)
and
Subsection
256(1)
and
its
Conditions
The
Board
concludes
first
of
all,
and
the
parties
are
of
the
same
opinion,
that
paragraphs
(a),
(b),
(c)
and
(d)
of
subsection
39(4)
(old
Act)
and
subsection
256(1)
(new
Act)
are
not
applicable
in
this
case,
that
is,
that
the
three
appellant
companies
cannot
be
deemed
to
be
associated
under
these
paragraphs.
The
paragraph
at
issue
is
paragraph
(e).
Analysis
of
this
paragraph
reveals
three
conditions
for
companies
to
be
associated:
(1)
each
corporation
must
be
controlled
by
a
related
group;
(2)
each
of
the
members
of
one
of
the
related
groups
must
be
related
to
all
of
the
members
of
the
other
related
group;
(3)
(a)
with
respect
to
the
1971
taxation
year,
one
of
the
members
of
one
of
the
related
groups
must
own
directly
or
indirectly
one
or
more
shares
of
the
capital
stock
of
each
of
the
corporations;
(b)
with
respect
to
the
1972
and
1973
taxation
years,
one
of
the
two
related
groups
must
own
directly
or
indirectly,
in
respect
of
each
corporation,
not
less
than
10%
of
the
issued
shares
of
any
class
of
the
capital
stock
thereof.
6.
The
Three
Conditions
in
Relation
to
the
Appellants
Do
the
above-mentioned
three
conditions
apply
to
the
three
appellants,
that
is,
between
J-Euclide
Perron
Ltée
and
Les
Immeubles
Perron
Ltée,
between
J-Euclide
Perron
Ltée
and
Mars
Finance
Inc
and
between
Les
Immeubles
Perron
Ltée
and
Mars
Finance
Inc?
6.1
Are
J-Euclide
Perron
Ltée
and
Les
Immeubles
Perron
Ltée
associated?
Are
the
above-mentioned
three
conditions
satisfied?
6.1.1
First
Condition
Is
each
of
these
corporations
controlled
by
a
related
group?
The
answer
must
be
in
the
affirmative
in
accordance
with
paragraphs
251(2)(a)
and
256(4)(a)
of
the
new
Act.
J-Euclide
Perron
Ltée,
on
the
one
hand,
is
controlled
by
the
three
Perron
brothers:
Fernand,
Georges-Henri
and
André.
Les
Immeubles
Perron
Ltée,
on
the
other
hand,
may
be
controlled
by
several
different
related
groups:
(a)
the
Perron
sisters
and
their
mother;
(b)
Les
Placements
du
Moulin
Ltée
and
the
Perron
sisters;
(c)
Les
Placements
du
Moulin
Ltée
and
Mrs
J-Euclide
Perron.
The
respondent
alleges
in
support
of
his
assessments,
as
appears
in
his
reply
to
the
application
of
the
applicants,
two
of
these
three
groups
(paras
(e)
and
(g)
of
subsec
(3)),
that
is,
the
Perron
sisters
and
their
mother
and
Les
Placements
du
Moulin
Ltée
and
the
Perron
sisters.
In
accordance
with
the
decisions
rendered
in
British-American
Tobacco
Co
Ltd
v
IRC,
[1943]
All
ER
13,
Buckerfield’s
Limited
et
al
v
MNR,
[1964]
CTC
504;
64
DTC
5301,
and
Yardley
Plastics
of
Canada
Lid
v
MNR,
[1966]
CTC
215;
66
DTC
5183,
the
Minister
cannot,
in
support
of
his
assessments,
choose
more
than
one
group
that
is
in
a
position
to
exercise
control.
In
Yardley
Plastics
of
Canada
Ltd
v
MNR
(supra),
Noël,
J
had
the
following
to
say
[at
p
224
[5188]]:
I
do
not
believe,
as
submitted
by
counsel
for
the
Minister,
that
the
latter
is
allowed
to
choose
out
of
several
possible
groups
any
aggregation
holding
more
than
50%
of
the
voting
power,
even
if
the
members
of
the
group
are
common
shareholders
in
both
corporations
and
that
such
a
group
then
becomes
irrebuttably
deemed
to
be
the
controlling
group
for
the
purposes
of
Section
39(4)
of
the
Act
as
this
could
lead
to
an
absurd
situation
where
no
two
large
corporations
in
this
country
would
be
safe
from
being
held
to
be
associated.
When
several
groups
may
possibly
have
legal
control,
that
is,
hold
the
majority
of
shares,
the
Board
concludes
that
it
is
necessary
to
choose
the
one
that
has
de
facto
control,
that
is,
the
one
that
sets
the
policy
that
must
be
followed
by
the
corporation’s
board
of
directors.
The
appellants’
evidence
on
this
point
has
clearly
established
that
the
group
formed
by
the
Perron
sisters
and
their
mother
set
the
company’s
policy
de
facto.
The
Perron
brothers,
through
Les
Placements
du
Moulin
Ltée,
tried
several
times
to
impose
their
policy
of
long-term
investments.
The
Perron
sisters
and
their
mother
always
opposed
this,
favouring
a
policy
of
short-term
investments
and
regular
dividend
issues.
The
Perron
brothers
tried
several
times
to
acquire
a
majority
of
the
shares
of
Les
Immeubles
Perron
Ltée,
but
failed.
Control
of
Les
Immeubles
Perron
Ltée
by
the
Perron
sisters
and
their
mother
goes
back
almost
to
creation
of
the
company.
The
evidence
shows
that
the
father,
J-Euclide
Perron,
had
formed
this
company
so
that
his
daughters
and
their
mother
would
have
control
of
it.
On
the
other
hand,
Les
Placements
du
Moulin
Ltée
(which
has
the
same
purposes
as
the
other
corporation)
was
formed
to
be
controlled
by
the
Perron
brothers.
The
Board
concludes
that
the
group
composed
of
the
Perron
sisters
and
their
mother
should
be
considered
as
the
one
controlling
the
company,
thus
eliminating
the
other
two
groups.
6.1.2
Second
Condition
Is
each
member
of
one
of
the
related
groups
related
to
all
the
members
of
the
other
related
group?
There
is
no
doubt
that
each
member
of
the
group
of
the
Perron
brothers,
controlling
J-Euclide
Perron
Ltée,
is
related
to
each
of
the
other
group
controlling
Les
Immeubles
Perron
Ltée,
the
Perron
sisters
and
their
mother.
Ail
these
people
are
connected
by
blood
relationship
for
the
purposes
of
paragraph
139(5a)(a)
(RSC
1952,
c
148
as
amended)
and
paragraph
251
(2)(a)
(SC
1970-71-72,
c
63
as
amended).
6.1.3
Third
Condition
Was
one
share
in
1971
and
10%
or
more
of
the
shares
in
1972
and
1973
of
a
company
owned
directly
or
indirectly
by
the
related
group
(not
less
than
10%
in
1972
and
1973)
and
by
a
person
(one
share
in
1971)
from
the
other
related
group?
No
member
of
the
related
group
controlling
Les
Immeubles
Perron
Liée
owned
a
share
of
J-Euclide
Perron
Ltée
in
1971
directly
or
indirectly,
nor
did
this
same
related
group
own
10%
or
more
of
the
capital
stock
of
the
same
company,
J-Euclide
Perron
Ltée,
in
1972
and
1973
directly
or
indirectly.
Can
the
same
be
said
of
the
related
group
controlling
J-Euclide
Perron
Ltée
with
respect
to
Les
Immeubles
Perron
Ltée?
The
Board
agrees
with
the
two
parties
that
there
is
no
ownership
of
a
share
(1971)
or
ownership
of
10%
or
more
(1972
and
1973),
because
of
the
judgments
handed
down
in
Army
and
Navy
Department
Store
Ltd
v
MNR,
[1953]
CTC
293;
53
DTC
1185,
and
Salomon
v
Salomon,
[1897]
AC
22,
even
though
the
Perron
brothers,
through
Les
Placements
du
Moulin
Ltée,
hold
49%
of
the
shares
of
Les
Immeubles
Perron
Ltée.
Lord
Macnaghten
had
this
to
say
in
Salomon
v
Salomon
(supra):
.
.
.
the
company
is
not
in
law
an
agent
of
the
subscribers
or
trustees
for
them.
Cartwright,
J
also
said
the
following
in
the
Army
and
Navy
case
(supra)
[p
308
[1193]]:
With
the
greatest
respect
for
those
who
hold
the
contrary
view,
I
do
not
think
that
shareholders,
either
individually
or
collectively,
have
any
ownership
direct
or
Indirect
in
the
property
of
the
company
in
which
they
hold
shares.
The
respondent,
however,
maintains
that
Les
Immeubles
Perron
Ltée
and
J-Euclide
Perron
Ltée
are
associated
under
the
terms
of
subsection
39(5)
of
the
old
Act
and
subsection
256(2)
of
the
new
Act.
The
respondent
claims
that
Mars
Finance
Inc
is
associated
with
both
Les
Immeubles
Perron
Ltée
and
J-Euclide
Perron
Ltée;
this
would
create
a
presumption
of
association
between
these
last
two
corporations.
Let
us
see
if
this
claim
is
valid
on
the
basis
of
the
facts.
6.2
Are
Les
Immeubles
Perron
Ltée
and
Mars
Finance
Inc
associated?
Have
the
previously
mentioned
three
conditions
been
met?
6.2.1
First
Condition
Are
both
corporations
controlled
by
a
related
group?
In
the
case
of
Les
Immeubles
Perron
Ltée,
as
we
have
already
seen,
the
Perron
sisters
and
their
mother
are
connected
by
blood
relation-
Ship.
In
the
case
of
Mars
Finance
Inc,
on
the
other
hand,
the
Board
cannot
find
enough
shareholders
(corporations
and
individuals)
related
to
one
another
and
in
a
position
to
control
this
corporation
by
holding
more
than
50%
of
its
capital
stock.
The
respondent’s
attempt
to
lump
together
all
the
shareholders,
with
the
exception
of
the
“outsiders”
(48.13%),
and
thus
form
a
group
holding
51.87%
of
the
shares,
cannot
be
accepted.
As
decided
above,
once
the
Perron
sisters
and
their
mother
are
found
to
be
the
only
group
able
to
control
Les
Immeubles
Perron
Ltée,
it
is
no
longer
possible
for
Les
Immeubles
Perron
Ltée
(10.32%)
and
Les
Placements
du
Moulin
Ltée
(1.76%)
to
be
associated,
and
consequently
it
is
no
longer
possible
for
Les
Immeubles
Perron
Ltée
and
J-Euclide
Perron
Ltée
(20.21%)
to
be
related
through
Mars
Finance
Inc.
Since
Les
Placements
du
Moulin
is
no
longer
part
of
the
group
controlling
Les
Immeubles
Perron
Ltée,
it
is
not
possible
for
these
two
corporations
to
be
related
under
the
terms
of
subparagraph
139(5a)(b)(ii)
of
the
1971
Act
and
subparagraph
251
(2)(b)(ii)
of
the
1972
Act.
Since
these
corporations
are
not
associated,
it
is
no
longer
possible
for
J-Euclide
Perron
Ltée
and
Les
Immeubles
Perron
Ltée
to
be
associated
under
subsection
139(5b)
of
the
1971
Act
and
subsection
251(3)
of
the
1972
Act.
These
sections
provide
that
two
corporations
are
related
if
each
one
is
related
to
the
same
third
one,
which
in
this
case
is
Les
Placements
du
Moulin
Ltée.
Further,
no
other
section
can
associate
Les
Immeubles
Perron
Ltée
with
either
Les
Placements
du
Moulin
or
J-Euclide
Perron
Ltée.
In
view
of
these
considerations
regarding
the
shareholders
of
Mars
Finance
Inc,
the
Board
concludes
that
it
is
impossible
to
form
a
related
group
capable
of
controlling
Mars
Finance
Inc,
and
that
it
is
therefore
impossible
to
satisfy
the
first
condition
of
paragraph
39(4)(e)
of
the
1971
Act
and
paragraph
256(1
)(e)
of
the
1972
Act.
6.2.2
Second
and
Third
Conditions
Since
the
third
condition
cannot
be
satisfied,
and
all
three
conditions
must
be
met,
the
Board
concludes
that
Mars
Finance
Inc
and
Les
Immeubles
Perron
Ltée
are
not
associated
corporations.
6.3
Are
Mars
Finance
Inc
and
J-Euclide
Perron
Ltée
associated?
Are
the
above-mentioned
three
conditions
satisfied
in
this
case?
Because
of
the
above
reasoning,
given
the
fact
that
the
first
condition
laid
down
by
paragraph
39(4)(e)
of
the
1971
Act
and
paragraph
256(1)(e)
of
the
1972
Act
cannot
be
met,
that
is,
inter
alia,
that
Mars
Finance
Inc
cannot
be
controlled
by
a
related
group,
there
is
no
point
in
examining
the
other
conditions
in
an
attempt
to
determine
whether
Mars
Finance
Inc
and
J-Euclide
Perron
Ltée
are
associated.
The
Board
must
conclude
that
Mars
Finance
Inc
and
Les
Immeubles
Perron
Ltée
are
not
associated
corporations.
6.4
Are
Les
Immeubles
Perron
Ltée
and
J-Euclide
Perron
Ltée
indirectly
associated?
The
respondent’s
above-mentioned
claim
that
Les
Immeubles
Perron
Ltée
and
J-Euclide
Perron
Ltée
are
indirectly
associated,
since
each
is
directly
associated
with
Mars
Finance
Inc,
cannot
be
accepted
because,
as
explained
above,
Mars
Finance
Inc
and
Les
Immeubles
Perron
Ltée
are
not
associated.
Subsection
39(5)
of
the
1971
Act
and
subsection
256(2)
of
the
1972
Act
are
therefore
not
applicable.
The
Board
must
accordingly
conclude
that
Les
Immeubles
Perron
Ltée
and
J-Euclide
Perron
Ltée
are
not
deemed
to
be
associated
with
each
other.
Because
of
the
above
considerations,
the
other
corporations
cannot
be
deemed
to
be
associated
either.
7.
Appeal
Allowed
In
view
of
the
evidence
adduced
and
study
of
the
Act
and
the
case
law,
the
Board
concludes
that
the
applications
of
the
appellant
companies
should
be
allowed,
and
orders
respondent
to
amend
the
assessments
in
question
accordingly,
the
whole
subject
to
agreement
between
the
parties
as
to
the
amounts
involved.
Appeals
allowed.
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