Guy Tremblay:—Cette cause fut entendue à Montréal (Québec) le 16 mai 1978.

Guy Tremblay:—This case was heard at Saskatoon, Saskatchewan, on October 12, 1978.

Guy Tremblay:—These appeals were heard at Vancouver, British Columbia, on February 22, 1979.

The Chairman:—The issues being identical, the appeals of Messrs Tapani Nestor Valitalo and Jose Murillo from assessments in respect of the 1974 and 1975 taxation years were heard simultaneously.

The Chairman:—Ceci est l’appel de M Jean-Louis Boivin à l’encontre des cotisations émises en date du 9 février 1976 pour les années d’imposition 1969, 1970, 1971, 1972 et 1973.

Guy Tremblay:—Cette cause fut entendue à Québec (Québec) le 13 septembre 1978.

Delmer E Taylor:—This is an appeal heard at the City of Toronto, Ontario, on February 27, 1979, from an income tax assessment in which the Minister of National Revenue increased the reported taxable income of the appellant for the year 1976

M J Bonner:—The appellant was assessed to income tax on the basis that gains realized in 1973, 1974 and 1975 on the disposition of the lake front property and cottage on Roderick Avenue in or near Sudbury, Ontario were income. The

M J Bonner:—The issue in this appeal is whether the sum of $28,850, being the price fixed by an agreement dated August 1, 1973, between the appellant and Black & Armstrong Limited (hereinafter “Black”) for the purchase by the appellant of,

M J Bonner:—The appellant appeals from assessments of income tax for the 1973 to 1976 taxation years, both inclusive. The assessments were made on the basis that the deduction of losses from the appellant’s horse racing business was restricted by