A W Prociuk (orally):—The appellant appeals from the Minister’s assessment with respect to the taxation years 1967, 1968 and 1969 when the Minister added to her declared income the sums of $5,440, $5,436 and $5,436 for each year respectively

The Assistant Chairman:—As I understand this appeal there is between the parties no substantial dispute except for those points I will shortly mention and, for that reason, I see no purpose in mentioning a lot of points covered by evidence.

Roland St-Onge (orally: July 7, 1976):—The appellant company appeals from the respondent’s reassessment in respect of the 1973 taxation year and the point at issue involves a real estate transaction.

Delmer E Taylor:—This is an appeal from income tax reassessments for the years 1972 and 1973. The matter at issue for the year 1972 is the income tax on an amount of $17,935.54 added by the respondent to the reported taxable income of the appellant.

A J Frost:—These appeals, which were heard in camera, are from Notices of Reassessment dated November 19, 1974 with respect to the appellant’s 1970 taxation year, wherein (a) a loss on the inventory of marketable securities in the amount of

Roland St-Onge:—This appeal is from reassessments bearing date July 28, 1973, wherein taxes in the sum of $244,706.88, $166,909.58, $85,180.97 and $28,453.75 were levied in respect of income for the taxation years 1967, 1968, 1969 and 1970 respectively.

Guy Tremblay:—The case at bar was heard in Sherbrooke, Quebec on April 28, 1976.

Guy Tremblay:—This case was heard in Montreal, Quebec on Aoril 8, 1976.

Guy Tremblay:—This case was heard at Quebec City on January 22, 1976.

Delmer E Taylor:—These are appeals from income tax assessments for the years 1969, 1970 and 1971. The matter at issue is whether the appellant’s interest in certain assets related to motel operations in Banff National Park, Province of Alberta should be, for purposes