M J Bonner:—The appellant was, at all relevant times, an employee of Edgar T Alberts Limited, which I will call “the Company” hereafter in these reasons.

Roland St-Onge:—The appeal of H Fine and Sons Limited came before me at the City of Ottawa, Ontario on November 29, 1978 and January 30, 1979 and it is with respect to the selling of land in the appellant company’s 1973 taxation year.

M J Bonner:—This is an appeal from an assessment made April 26,1977, of a penalty under subsection 163(2) of the Income Tax Act in respect of the appellant’s 1972 tax return. The burden of proof of the facts justifying

M J Bonner:—This is an appeal from an assessment of income tax and penalty for the appellant’s 1972 taxation year. Notice of the assessment was dated July 22, 1975. In computing income the Respondent included, pursuant to subsection 15(1) of

M J Bonner:— The issues are the same in each of these appeals. They are whether revenues from the sale by the appellant of certain oriental rugs were revenues from a business or were receipts on capital account.

M J Bonner:—This is an appeal from an assessment of tax for the appellant’s 1975 taxation year.

Guy Tremblay:—Cette cause fut entendue à Québec (Québec) les 14 et 15 septembre 1978.

Delmer E Taylor:—This appeal was heard December 6,1978, at the City of London, Ontario, and deals with income tax assessments in which the Minister of National Revenue disallowed amounts of $16,746.81 and $109,186.95 for the taxation years 1973 and

The Assistant Chairman:—John Jenkins, a medical doctor (the “appellant”), has appealed to this Board from an assessment for tax for each of the 1971,1972 and 1973 taxation years. The appellant, on November 1,1971, became “associated” with a partnership

M J Bonner:—These are appeals from assessments of income tax for the appellant’s 1973, 1974, 1975 and 1976 taxation years. The appellant is the son of the late Ethel Jane Brown whose will provided that: