Cattanach, J:—This is an appeal by Her Majesty the Queen from a decision of the Tax Review Board dated September 12, 1975 with respect to the assessment of the defendant to income tax by the Minister of National Revenue for the defendant’s

Addy, J:—The plaintiff, a United States company, was taxed for the years 1969 to 1972 inclusively under Part III of the Income Tax Act, RSC 1952, c 148 (hereinafter referred to as the “former Act”) and, subsequently, under Part

The Chief Justice (orally for the Court):—We do not need to hear you Mr Chalmers and Mr Pyrcz. We agree with the reasons for judgment of Gibson, J and accordingly the appeal is dismissed with costs.

The Chief Justice (judgment delivered from the Bench) (concurred in by Pratte, J and Hyde, DJ):—Except as hereinafter set out, the circumstances in this appeal do not differ materially from those in The Queen v Rockmore

The Chief Justice (judgment delivered from the Bench) (concurred in by Pratte, J and Hyde, DJ):—This is an appeal from a judgment of the Trial Division allowing an appeal from the respondent’s assessment under Part I of the Income

Le Daln, J (judgment delivered from the Bench) (concurred in by Heald and Ryan, JJ):—This is a section 28 application to review and set. aside an order, pursuant to subsection 232(6) of the Income Tax Act, to a

Collier, J:—The plaintiff is a barrister and solicitor. In 1972 and prior years he practised his calling in Windsor, Ontario. His business was and is “a profession”.f [1] In the taxation years previous to January 1, 1972 he had

The Chief Justice (judgment delivered from the Bench) (concurred in by Pratte, J and Hyde, DJ):—This is an appeal from a judgment of the Trial Division dismissing an appeal by the appellant from assessments under Part I of the Income

Dubé, J:—This is an appeal from a reassessment of the plaintiff’s income tax for the 1968 and 1969 taxation years. By Notices of Reassessment dated March 24, 1971 the Minister reassessed the plaintiff (hereinafter “Regal’’) on the basis that it was

Gibson, J:—For the reasons given in the case of Plan A Leasing Limited v Her Majesty the Queen (Court No T-2224-75) this date, this appeal is allowed with costs, and the matter is directed to be referred back for reassessment not inconsistent with the reasons.