Marceau, J:—These are income tax cases. By order of this Court, the two appeals* [1] were to be heard together, on common evidence, as they both related to the same facts.

Grant, DJ:—This is an appeal by the plaintiff from the judgment of the Tax Review Board dated June 4, 1976 whereby that Board allowed the defendant Woods’ appeal from the assessment of his income tax returns for the years 1969, 1970 and 1971

Mahoney, J:—The applicants seek, in these proceedings, an order to remove into this Court and quash an approval given February 28, 1977 by His Honour Judge Cornish of the County Court of the Judicial District of York pursuant to subsection 231(4)

Walsh, J:—This is a motion by plaintiff for reconsideration pursuant to Rule 337(5) of this Court of a judgment rendered on September 20, 1977, dismissing her motion for an order extending the time within which an appeal might be made from the

The Chief Justice (concurred in by MacKay and Kelly, DJJ) (judgment delivered from the Bench):—This is an interlocutory application made in the course of a section 28 application. It is expedient to outline the proceedings preceding the interlocutory

The Associate Chief Justice:—The issue in this appeal is whether the defendant is entitled, under Arctile VIII A of the Canada-United States Reciprocal Tax Convention, to exemption from Canadian income taxation in respect of his income from teaching

Collier, J:—In November of 1955 Harold and Jacob Borinsky, brothers, along with Max Borinsky, Jacob’s son, bought a farm of roughly 154 acres. The purchase price was approximately $175,000. By 1969, about 140 acres remained. In that year the property was

Maguire, DJ:—On the hearing of this appeal, and with the consent of counsel for the Crown, Her Majesty the Queen was substituted as defendant in the place of the Minister of National Revenue.

Dube, J:—The issue to be determined in this case is whether the defendant can set off against the plaintiff’s claim for drawbacks the unrelated indebtedness of Rapid Data Systems & Equipment Limited for income tax and excise tax which arose prior

Addy, J:—The plaintiff is appealing a decision of the Tax Review Board under which the Minister’s assessment was reversed and a claim for expenses by the defendant company in the amount of $128,000 was allowed for the taxation year 1971.