A J Frost (orally: May 4, 1977):—I shall now give my decision in Appeals Nos 76-119 and 76-120 between Mendel Tenenbaum and Hersz Tenenbaum, appellants, and the Minister of National Revenue, respondent. These are income tax appeals with respect to

Guy Tremblay [TRANSLATION]:—The case at bar was heard at Quebec City on May 6, 1977. The evidence was heard concurrently with that of the case of Estate of Claude Gingras (76-755).* [1] Both men

Guy Tremblay [TRANSLATION]:—This case was heard at Montreal, Quebec, on June 6, 1977.

Delmer E Taylor:—This is an appeal against an income tax reassessment for the year 1972 in which the Minister of National Revenue denied to the appellant a claim for refundable dividend tax in the amount of $13,246. The appellant relied upon

A J Frost (orally: July 4, 1977):—I shall now give my decision in Appeal No 76-920 between Harold Adams, appellant, and the Minister of National Revenue, respondent.

Delmer E Taylor:—This is an appeal from income tax reassessments for the years 1971, 1972, 1973 and 1974, in which the Minister of National Revenue changed the taxable income of the appellant by the following:

Delmer E Taylor:—This appeal is in respect of the 1973 and 1974 taxation years, and the points raised by the appellant were:

The Chairman:—This is the appeal of D G Cowan from an income tax assessment in respect of the 1972 taxation year.

Guy Tremblay [TRANSLATION]:—The case at bar was heard at Quebec City on May 13, 1977.

The Chairman:—This is the appeal of Wallace R Brunelle from an income tax assessment in respect of the 1973 taxation year which was heard simultaneously with the appeal of Peter Brunelle for the same taxation year. Both appeals deal with the