Guy Tremblay:—This case was heard at Ottawa, Ontario, on December 4, 1978.

Walsh, J:—These six actions were by order pursuant to Rule 1716 joined for simultaneous hearing on common proof. The only issue is one of fact namely the appropriate division of the purchase price of property situated at 5110 to 5830 Second Avenue,

Marceau, J:—The plaintiff is a trust established in 1942 by one Samuel Bronfman in favor of his daughter. Pursuant to the deed of trust, the latter, as the institute, is entitled to receive annually 50% of the revenues from the trust property

Morrow, J:—The present appeal is by way of a stated case from provincial court Judge M Horrocks who heard three charges against the respondent under subsection 150(2) of the Income Tax Act, RSC 1952 as amended, and who

Grant, DJ:—Three motions are before the court for consideration at this time. They are as follows:

Marceau, J:—This action—which was appealed from a decision of the Tax Review Board upholding a reassessment dated November 7, 1974, made on plaintiff by the Minister for the 1971 taxation year—concerns the interpretation and application of two provisions of

Dube, J:—This is an appeal from an assessment by the Minister of National Revenue on appellant’s income for 1962.

Walsh, J:—These two actions which are appeals from income tax assessments of appellant Hummel Corporation of Quebec Limited for the years ending December 31, 1970, 1971 and 1972 respectively and Hummel Estate Corporation of Canada Limited for the same years were joined

Cattanach, J:—It is apparent from the pleadings herein that this is an appeal from a decision (or perhaps four decisions) of the Tax Review Board dated February 16, 1979 whereby the plaintiff’s appeals from assessments to income tax for his 1973,

Heald, J:—This is a section 28 application to review and set aside a decision of the Tax Review Board (hereafter the Board) made by F J Dubrule, QC, Assistant Chairman of the Board on April 6, 1979. The pertinent facts may be summarized as follows: