Bowman J.T.C.C.:-The central issue in all of these appeals which were heard together is the fair market value at December 31, 1971 (valuation day, or V-day) of a number of parcels of land owned by the appellants in Delta, British Columbia at or near to the intersection of Highway 17 and 60th Avenue. Other issues arise but they are for the most part subsidiary to that central issue.
Appendix A [not reproduced] to these reasons is a site plan showing the location of the various parcels in question, designated by the letters A, B, C, D, E, F, G and H, letters used by the appellants’ expert. The respondent’s expert designated the parcels by numbers, which correspond to the letters as follows: 1-A, 2-B, 3-H, 4-G, 5- E, 6-F, 7-C, 8-D.
The specific issues relating to each appellant are as follows:
A. Grove Crest Farms Limited (Grove Crest)-1988 and 1989
The shareholders of this company at all material times were:
James Harris: 42%
Arlene Kyan: 26%
(sister of James and David Harris) David Harris: 12%
Pauline Harris: 20%
(mother of James and David Harris and Arlene Kyan)
On December 31, 1971 Grove Crest owned a 50 per cent interest in parcels A, B, C, D, E, F, and G. In 1988 it sold its 50 per cent interest in parcels A, B, E and F to a company, Nomada-Gumi Construction with which it dealt at arm’s length. Grove Crest’s share of the proceeds was $563,000. Grove Crest in filing its return of income for 1988 reported no capital gain on the disposition, taking the position that the V-day value of the properties was $804,000. The Minister of National Revenue assessed on the basis that these four parcels had a V-day value of $349,900 and that the appellant’s interest therein had a V-day value of $174,950.
In 1975 parcel C was traded with the Ministry of Highways and parcel H was received in substitution therefor. The Minister assumed there was no gain or loss on the disposition of parcel C.
In 1989 Grove Crest, as part of a distribution on winding-up, transferred its 50 per cent interest in parcel H to James Harris and its 50 per cent interest in parcel G to Arlene Kyan and David Harris. The appellant took the position that the valuation day value of its 50 per cent interest in the two parcels distributed in 1989, (G and H) was greater than the fair market value thereof on the date of distribution with the result that no capital gain was realized. It is not clear what relevance the V-day value of parcel H has, considering that it was not acquired until 1975. If it was a replacement property within the meaning of section 44 of the Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.) (the "Act”) the V-day value of the former property might have been relevant. This position was not taken and accordingly the value of parcel H in 1975 when it was given in exchange for parcel C on the disposition of the latter was treated as the cost base of the former when it was disposed of in 1989.
B. James Harris-1987, 1988 and 1989
On the winding-up of Grove Crest it distributed to James Harris its 50 per cent interest in parcel H. The issue is the value of that property on the date of distribution for the purpose of computing the dividend deemed to have been received by him in 1989. Relevant as well to the amount of the deemed dividend is the amount of Grove Crest’s capital surplus on hand and its capital dividend account which in turn is affected by the V-day value of the lands owned by the company.
In addition the appellant James Harris owned a 50 per cent in certain of the parcels which were sold or disposed of in 1988 and 1989. The issue is the V-day value of these properties and their value when he disposed of them, to the extent that they were disposed of to non-arm’s length purchasers.
The other issues relating to shareholder’s loans and a deduction under paragraph 20(1)(j) were not challenged.
C. Pauline Harris-1988, 1989 and 1990
The issues here are substantially the same as some of those in the case of James Harris and have to do with the amount of the deemed dividend received by her in the winding-up of Grove Crest. Other issues relating to shareholder’s loans were abandoned.
D. Arlene Kyan-1988 and 1989
The only remaining issue here is the amount of the deemed dividend received by the appellant in 1989. This in turn depends on the determination of the value on V-day and in 1989 of the lands disposed of by Grove Crest. The other issues were abandoned. The assessment for 1988 was nil and no appeal lies from a nil assessment. The respondent incorrectly contended that this was a matter of the court’s lacking jurisdiction. It has nothing to do with jurisdiction. It has to do with the appellant having nothing from which to appeal. The appellant agreed at trial to the dismissal of the appeal from Ms. Kyan’s 1988 assessment.
E. David Harris-1988 and 1989
Again, the issue is the amount of the deemed dividend received by David Harris on the winding-up of Grove Crest. In addition the appellant had a one-third interest in parcel D which he disposed of in 1989 in a non-arm’s length transaction. The issue therefor is the V-day value and the value in 1989 of his interest in parcel D. The shareholder’s benefit issue was abandoned.
Appendix B to these reasons sets out the values attributed to the various parcels on V-day and in 1989 by the parties. The expert valuator called by the appellant was Mr. Danny Grant. The expert valuator called by the respondent was Mr. John Weldon. Other appraisals were made by Revenue Canada, notably by Mr. Wong, for the purpose of the first assessment and Mr. Egelstad for the purpose of the second assessment. Only Mr. Weldon was called as a witness. Mr. Wong’s conclusions are not part of the evidence. Mr. Egelstad’s figures which formed the basis of the reassessments appealed from were put in evidence, but not his appraisal. Counsel for the respondent stated that where Mr. Weldon’s figures were less favourable to the appellants than those used in making the assessments appealed for she was not asking for additional tax (see Harris v. [1966] C.T.C. 226, 66 D.T.C. 5189).
Overview
The properties in question are all situate at or near the junction of Highway 17 and Highway 99 in the municipality of Delta, about 13 miles south of Vancouver. The intersection is a busy one. Highway 99 is the major north-south freeway linking Vancouver to the United States. Highway 17 links Highway 99 with the British Columbia Ferries terminal at Tsawwassen. Delta is a municipality forming part of Metropolitan Vancouver. Approximately one-quarter of its area consists of farmland. Its population was growing at a relatively rapid rate. Between 1971 and 1976 it grew from 46,000 to 64,000.
Mr. Grant, in his report, referred to a number of factors that he considered significant in determining the value of the properties as of V-day. These factors were:
1. In 1968, development of the Roberts Bank Superport began, and upon completion in 1970, became one of the largest bulk loading ports in North America. In addition to the original 4,000 acres of land expropriated to facilitate the port, 6,000 acres of foreshore lands were designated for future port development.
2. Construction was completed to improve the Tsawwassen Highway between Highway 499 and the Tsawwassen Ferry Terminal, which included widening to four lanes with the addition of appropriate turning lanes and access roads.
3. Redyking of the perimeter of Boundary Bay and the Delta portion of the Fraser River was commenced.
4 Construction of the Delta Municipal Hall in 1968 and the Justice Building in 1972 at the intersection of Highway 17 and 48th Avenue was completed.
5. Construction of neighbourhood shopping centres and numerous commercial buildings within the Tsawwassen and Ladner commercial areas took place.
6. At valuation day, with the planned Superport development, anticipation of extensive development, employment and the requirement for related land requirements was a major market factor. Speculative purchases for land for all types of uses was the norm, particularly after the Crown had taken 4,000 acres from private lands for the one purpose alone.
Further purchases for green belts to pacify objectors to the Superport were carried out in 1971 or 1972. These were major market considerations until a socialist government was elected in August 1972 and froze all development in December 1972.
I regard items 1, 2, 5 and 6 as being of greater importance than items 3 and 4.
One of the most significant events was the freeze on development that took place following the election in August 1972. The freeze itself is not relevant to the V-day value, because it was subsequent to V-day, but it affects the weight that one can put on sales that took place after December 1972. Following the freeze on the development of agricultural farmlands, the provincial government created a land commission and established an Agricultural Land Reserve (ALR). Agricultural lands included in the ALR had to be removed from it if they were to be developed for some purpose other than farm use.
At V-day all of the lands in question were zoned A-l (agricultural) and on the regional plan were designated RRL (lowland rural area). They were all part of a farm that had been in the Harris family for five generations. They were actually farmed. Grove Crest Farms is one of the largest potato producers in British Columbia. I accept Mr. Grant’s opinion that they were well located for commercial or residential development. Their location would make them attractive subjects for speculative purchasers. The probability or possibility, if any, of obtaining zoning for commercial uses would be a factor that would influence a speculative purchaser. In determining the fair market value of property at a particular point in time the Court must postulate the existence of a hypothetical willing and knowledgeable vendor and a hypothetical willing and knowledgeable purchaser, neither of whom is under any compulsion, and, based upon the evidence, including the opinions of experts, attempt to determine what price they would have negotiated. The question that must be determined is what these two hypothetical persons would perceive to be the chances of obtaining commercial zoning on December 31, 1971 and how their perception of those chances would affect the deal that they would theoretically have struck on that day. With the benefit of hindsight one would have to conclude that, in light of subsequent events, the chances were virtually non-existent. The hypothetical vendor and purchaser did not have that knowledge of subsequent events on December 31, 1971 and the conclusion must be based upon the knowledge that they would be presumed to have had at that time.
The single most important factor that separated Mr. Grant and Mr. Weldon was the highest and best use of the subject properties. This in turn was affected by their view of the possibility or probability of rezoning. Mr. Grant’s view of the highest and best use was as follows:
It is concluded that at the date of valuation, December 31, 1971, the highest and best use of the subject properties is as speculative holding properties pending development for predominantly commercial uses with continued interim use for commercial agriculture.
Mr. Weldon’s was the following:
Agricultural use with Nos. 4 and 8 having future potential for industrial development and Nos. 2 and 6 having some possibility for rezoning to a commercial highway travel use.
Highest and best use is a concept used in the valuation of land. It has been expressed in various ways in the cases to which counsel referred me. It means merely the highest economic use to which the land may reasonably be expected to be put. The two experts approached the concept from somewhat different directions, neither one of which 1s altogether satisfactory. Mr. Grant described the highest and best use as "speculative holding properties pending development for predominantly commercial uses with continued interim use for commercial agriculture". This enigmatic statement covers all bases without conveying any information. Speculative holding is not a use at all. Mr. Weldon did not do much better. He determined the highest and best use on the basis not of the land’s economic potential but on the basis of its zoning.
In the final analysis I did not derive much help from either of these two philosophically different approaches. It would seem to me that the determination of highest and best use in the context of determining the value of land involves a two step process:
A. What is the highest economic use to which the land can reasonably be put, leaving aside the existing zoning?
B. If the existing zoning permits that use, no further enquiry need be made. If not, what effect does the existing zoning have? How does the possibility or probability of rezoning, or the lack thereof, affect the likelihood of the lands being put to that use?
My conclusion, based upon the evidence of persons who were knowledgeable in the real estate market in 1971, is that the properties, or at least some of them, had a potential for redevelopment as commercial property. We must consider the situation as of December 31, 1971. The land freeze, following the change in government in 1972 and the subsequent establishment of the ALR was not reasonably foreseeable on V-day and could not have been anticipated. The events in 1972 had the effect of dampening the price of properties bought for speculative purposes and for that reason sales after those events should be treated with caution. That said, the values per acre determined by Mr. Grant reflect an optimism as to the chances of commercial rezoning that is not altogether justified by the evidence of such witnesses as Mr. Tom Goode, the mayor of Delta in 1972 and for several years thereafter. While one cannot be categorical in characterizing a municipal council as "pro-development” as opposed to "nogrowth" it appeared to me that any developer purchasing the lands on December 31, 1971 could not anticipate that any application for rezoning of the subject lands to commercial, residential or even industrial from agricultural would have an easy passage. By the time Mr. Goode became mayor in 1972 the council of Delta was, as he put it, "no-growth", and at least one half of the members of that council were members on V-day.
Conversely, I think Mr. Weldon’s V-day values do not take into account sufficiently the speculative value of the subject lands which, situate at the intersection of two busy highways, were in a good location for commercial development. There were already three major commercial developments adjacent to one of the subject properties, parcel F-a motel, a Shell service station and a Chev-Olds dealership. I accept Mr. Grant’s view that prices in the area were being pushed up by the development of a superport and by a relatively rapid increase in the population of Delta. I think some additional weight should be given to the value of the expectation that existed on December 31, 1971 that there was a reasonable possibility of rezoning of the subject lands as commercial.
V-day values
Parcels A (RC-1) and E (RC-5)
Parcel A, comprising 4.53 acres was valued as of V-day at $6,500 per acre by Mr. Egelstad, $3,000 per acre by Mr. Weldon and $11,100 per acre by Mr. Grant. It is contiguous to parcel E (RC-5), comprising 28.59 acres which was valued at $4,000 per acre by Mr. Egelstad, $3,500 per acre by Mr. Weldon and $6,500 per acre by Mr. Grant. It is not clear why parcels A and E were not valued as a unit. Mr. Grant concluded that parcel A was adversely affected by its shape and location and the heavy traffic on 64th Street going to and from the municipal dump. The garbage trucks also go past parcel E. He estimated the "site value" of parcel A at $50,000. It is not clear why it should have a value per acre of $11,100 whereas the larger parcel E would have a value of only $6,500 per acre. Mr. Weldon considered E to be somewhat more valuable than parcel A, notwithstanding its "inferior zoning potential". Indeed, Mr. Weldon considered that parcels A and C should be valued as a unit because of the existing and future access problems affecting parcel C (RC-7) which was severed from the rest of the farm by Highway 99. This does not seem to me to be reasonable. It appears to be more appropriate to value parcel A with parcel E.
The three comparable sales relied on most heavily by Mr. Grant in valuing parcel E were his comparables 1, 2 and 23. Comparable 23 was a 46.48 acre parcel and was located at 60th Avenue and 64th Street and it sold in February 1970 for $250,000, or $5,379 per acre. His comparables 1 and 2 (Mr. Weldon’s 10 and 12), also located on 60th Avenue are of less relevance in determining the value of parcels A and E. They were both sold to the Corporation of Delta and were both zoned industrial. Generally speaking I tend to be somewhat cautious in using sales to governmental bodies as an indication of what prices could be expected in the open market. Although comparable 23 (Mr. Weldon’s 5) was also zoned industrial I think that in the market that prevailed in December 1971 the comparable is some indication of what parcels A and E could have been sold for.
I put the value of A and E at $6,500 per acre on the basis that the sale of comparable 23 was about two years prior to V-day, but it was zoned industrial. This I think reflects a more reasonable premium that the commercial potential of the entire parcel would probably command.
Parcels B and F (RC-2 and 6)
These parcels, comprising a total of 49 acres were valued as a unit by both Mr. Weldon and Mr. Grant. Mr. Egelstad assigned a V-day value of $3,700 per acre, Mr. Weldon, $4,500 per acre and Mr. Grant, $12,000 per acre. They are obviously a unit.
Mr. Grant treated as the most relevant sale his comparable 4 (Mr. Weldon’s 13). Mr. Grant’s comparable 4, comprising 10.61 acres, and zoned industrial, was sold on November 2, 1970 to a hotel developer, Georgian Enterprises Ltd., for $100,000 or $9,425 per acre. The property was resold on May 1, 1973 for $180,000, or $16,965 per acre. Mr. Weldon did not consider the second sale of this comparable. Mr. Grant concludes from this double sale that the rate of increase was 2 per cent per month. The interval was 30 months and as a pure exercise in mathematics it works out to 1.85 per cent per month, assuming a constant rate of increase, which would give a V-day value to his comparable 4 of $12,900 per acre. He supports his conclusion as well by reference to his comparable 5, a parcel of 97 acres which was zoned industrial and sold for $10,623 per acre in August 1976. I do not regard this sale as particularly relevant. It took place in 1976, four and one half years after V-day. It was sold to Roberts Fisheries and had 900 feet of frontage on Deas Slough.
Mr. Weldon considered his comparable 1 as most relevant to parcels B and F. This comparable sold in April 1969 for $4,505 per acre. It was a large parcel comprising 324.80 acres and was located at the intersection of Highway 17 and 56th Street and was bought by the employees of a real estate company with rezoning in mind.
I regard Mr. Grant’s comparable 6 as being of somewhat greater relevance. It was sold in 1969 for $150,000, or $7,504 per acre. It comprises 19.99 acres and was zoned agricultural. It is some distance from B and F, but assuming a gradual increase in agricultural farm prices and taking into account a certain speculative premium for the subject lands, it would indicate a value on December 31, 1971 of $8,500 per acre for
parcels B and F.
I should comment briefly on certain options that were given to Royal Oak Holdings Ltd. on parcels B and F in 1974 and extended in 1976. The option price was originally $20,000 per acre and it was raised to $27,000 per acre when the option was extended, a total of $21,000 was paid for the options. I am not inclined to place much weight upon these options as an indication of the V-day value of parcels B and F. Certainly the price of $20,000 or $27,000 per acre, had the options been exercised, would have indicated a much higher value than any of the appraisers assigned to the properties, but they were not exercised: their exercise was economically contingent upon Royal Oak being able to have the property rezoned to permit a regional shopping centre. It was not successful in doing so and the option lapsed. Had it succeeded $20,000 or $27,000 per acre would have been a realistic price for a property from which the developer could have earned millions. $21,000 for the options was a modest gamble and relatively cautious commitment in the context of a potential multi-million dollar deal. It does not indicate a great deal of optimism about the chances of getting rezoning. The options do however confirm what I think is fairly obvious in any event-that an experienced developer saw the property as having an excellent location for a shopping centre.
Parcel C and H (RC-7 and 3)
Counsel stated that I need not consider the V-day value of parcel C because it was exchanged for parcel H in a transaction in 1975 with the Department of Highways. If its V-day value was irrelevant I am not sure just why all three appraisers determined its value as of that day. If parcel H was a replacement property for parcel C, the latter’s V-day value would have been relevant in determining the adjusted cost base of parcel H. As noted, that position was not taken and no further consideration need be given to parcel C. The value of parcel H on April 15, 1975 was treated as its adjusted cost base upon its disposition in 1989. Mr. Little informed me that the appellants were prepared to accept Mr. Weldon’s appraisal of parcel H as of April 15, 1975 of $295,100 or $4,500 per acre.
Parcel D and G (RC-8 and 4)
These two parcels, almost identical in size and shape, are separated from the rest of the farm, and are located at the corner of 60th Avenue and 64th Street. They are zoned agricultural. D is 12.26 acres and G 12.65 acres, for a total of almost 25 acres. D has frontage on both 60th Avenue and 64th Street whereas G fronts only on 60th Avenue.
Mr. Egelstad assigned a value of $5,000 per acre to each of D and G. Mr. Weldon valued D at $7,000 per acre and G at $6,500. Mr. Grant’s values were $9,000 per acre for D and $8,000 per G.
It is interesting to observe that parcels D and G were on V-day, according to Mr. Weldon, the most valuable of all of the seven parcels appraised whereas in Mr. Grant’s view they were significantly less valuable than parcels B and F. Moreover, the difference between Mr. Grant and Mr.
Weldon in respect of D and G was relatively small-between $1,500 and $2,000 per acre whereas the difference between them in respect of parcels B and F was substantial-$7,500 per acre.
The valuation of parcels D and G involves fewer imponderables than the valuation of the other parcels. They are of a regular shape, they front on two roads that are not limited access highways and they do not have the mixed blessing of being located at the interchange of two major four-lane highways. They did not have either the advantages or the disadvantages of being on such highways. They are both small enough that if considered separately they could command the higher price normally obtained for smaller parcels, yet if put together they had sufficient acreage to support a small farming operation, or if rezoning could be obtained, a moderately sized commercial development. Although zoned agricultural they were designated for industrial use in the Delta Plan Review.
I think that on V-day they had the best possibility of being rezoned for industrial use and possibly even for commercial use. Geographically the closest of Mr. Weldon’s comparables was his number 5, (Mr. Grant’s 23) a 46.48 acres parcel at the northwest corner of 64th Street and 60th Avenue. It sold in February 1970 for $250,000. Mr. Weldon considered that it was sold for $3,767 per acre whereas Mr. Grant calculated $5,379 per acre. The difference per acre is attributable to the fact that Mr. Weldon assigned a value of $74,900 to the improvements and Mr. Grant, nil. Mr. Weldon’s comparable number 10, (Mr. Grant’s 2) a parcel of 20.97 acres sold for $7,964 per acre on September 20, 1972. It was located on 60th Avenue and was zoned industrial. It is reasonably comparable to both D and G, although as stated above I tend to treat sales to municipalities with some caution. The same observation might be made about Mr. Weldon’s comparable 12 (Mr. Grant’s 1) which was also sold to Delta in October 1970 and was also industrially zoned. Mr. Weldon considered his comparable 13 (Mr. Grant’s 4) as the most relevant to D and G. It sold on November 2, 1970 for $9,425 per acre and was zoned industrial. I do not regard Mr. Weldon’s comparable 14, which was zoned agricultural, as being of any particular assistance. It is a long way from any of the subject properties and seems to have had little potential beyond its agricultural use. It sold for $4,200 per acre on December 22, 1971, within nine days of V-day. The same observation can be made of Mr. Weldon’s comparable 15, which sold on August 15, 1972 for $5,100 per acre. It is accepted that this property was, because of its location, inferior to D and G. It is of some passing interest that Mr. Grant’s comparable 21, which is adjacent to Mr. Weldon’s 15, sold in 1976 for over $12,000 per acre.
A number of Mr. Weldon’s other comparables, 16, 17, 18 and 19 were a considerable distance from the subject properties, were admitted by Mr. Weldon to be inferior to D and G and, in my opinion, are not sufficiently comparable to be of much assistance.
Mr. Weldon’s comparables 20 and 21 are closer to D and G and they sold for $7,384 and $7,680 per acre. Their location is inferior to that of D
and G but they were zoned industrial.
Mr. Grant considered that the most relevant comparables were his 20, 21 and 22 which sold at $7,627 per acre on June 3, 1976, $12,115 on June 1, 1976 and $7,914 on June 11, 1976 respectively. They were all zoned agricultural. They were all sold several years after V-day and are some distance from D and G. Their location appears inferior to D and G. They are of limited assistance in determining the value of D and G on December 31, 1971, but they do indicate that even for agriculturally zoned land the bottom did not exactly fall out of prices even after the agricultural land freeze and the establishment of the ALR.
Taking all of these factors into account I think that a fair value on V-day of parcel D is $8,000 per acre and, for parcel G, $7,000 per acre.
Improvements
I have not considered the value of the improvements. They were dealt with in the experts’ reports but not in the viva voce testimony or in argument. Mr. Weldon’s V-day value for the buildings was slightly higher than Mr. Grant’s. I can see no reason for differing from Mr. Weldon’s figures.
1989 values
It was agreed between counsel that the 1989 value of parcels D and G was $22,000 per acre.
Parcels A, B, E, and F, were sold in 1988 to Nomada-Gumi Construction and accordingly their value in 1989 need not be considered.
This leaves only parcel H which Mr. Egelstad valued at $492,000, or $7,500 per acre. Mr. Weldon valued it at $524,600, or $8,000 per acre and Mr. Grant valued it at $295,000, or $4,000 per acre. The value is for land only, since the improvements were owned by third parties.
Mr. Grant’s estimate-it is admittedly not a formal appraisal-of the value in 1989 is precisely the same as Mr. Weldon’s appraisal as of April 15, 1975, a value which the appellant accepts. Mr. Grant’s estimate of value appears to be premised on the assumption that between 1975 and 1989 there was no change in the value of this parcel which comprised 65.6 acres. This does not seem reasonable.
Both experts agree that the land was to be valued as agricultural land. Its highest and best use was the same as its zoning. There is no suggestion that by 1989, which was about 17 years after the land freeze and the establishment of the ALR, it had any speculative potential for any higher use.
Mr. Weldon analyzed eight sales in the Delta area in arriving at his value of $8,000 per acre. The closest geographically to parcel H is the sale by the appellants of parcels A, B, E and F to Nomada- Gumi Construction in 1988 at a price of over $14,000 per acre. This is, I think, the best indication of value of all of the comparables which he used. The price of the other comparables ranged from $4,570 per acre to $21,574 per acre. One cannot ignore the Nomada- Gumi Construction sale and, based on the comparables used by Mr. Weldon, there is no reasonable basis upon which I could conclude that the 1989 value of parcel H was less than $8,000 per acre, the figure determined by Mr. Weldon. As agreed by counsel for the respondent, the figure used on assessing of $7,500 per acre must stand.
Summary
The net result of these findings may be summarized as follows. The total values exclusive of buildings of parcels A, B, G, E, F, and D are:
V-day
Mr. Eglestad: $455,300 Mr. Weldon: $499,100 Mr. Grant: $1,038,000
as determined in this judgment: $818,410
1989 (Parcel H only)
Mr. Eglestad: $492,000 Mr. Weldon: $524,600 Mr. Grant: $295,000
As determined by this judgment: $524,600
As agreed the appeal from the 1988 assessment of Arlene Kyan is dismissed. The other appeals are allowed and the assessments referred back to the Minister of National Revenue for reconsideration and reassessment to the extent necessary to give effect to the findings in these reasons, provided that where the values determined herein would result in a treatment that is less favourable to the appellants than that accorded on assessing, the values used on assessing must be maintained.
Since success is divided the parties should bear their own costs.
Appeals allowed.
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