DUMOULIN, J.:—At the start of trial, the parties hereto moved that appeal number 145-751 of this Court’s records, between The Minister of National Revenue, appellant, and Allan Bronfman, respondent, serve mutatis mutandis as a pattern decision for the instant cases, both as to the facts and the pertinent law.
Therefore, these appeals are allowed as follows: the respondents will be assessed for a portion of the income tax attaching to the $97,000 donated, rateably to the number of shares owned, during the material years, of the total capital stock of Brintcan Holdings (Canada) Limited.
The records of the cases will be referred to the Minister for revision accordingly.
These appeals succeeding but partially, no costs are granted to either party.
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