Addy, J:—The plaintiff appeals his income tax assessment for the 1971 taxation year. The part of the assessment in issue before me pertains to a Capital cost allowance of $11,243.40 which the plaintiff claimed as a limited partner entitled to a

Mahoney, J:—The plaintiff disputes inclusion in its 1973 income tax assessment of the entire $441,860.61 gain realized on the sale of a parcel of real estate owned by it. The plaintiff has reported a taxable capital gain on the disposition in the

Walsh, J:—This concerns a garnishee order to show cause applied for by the solicitor for Her Majesty the Queen directed to the Royal Trust Company, 630 Dorchester Boulevard West, Montreal, to attach the amount of approximately $10,665.49 deposited in

Urie, J:—The hearing of the appeal was adjourned following the conclusion of argument to permit the Court to consider counsel’s submissions. We have done so and have, as well, reviewed the evidence at trial and the reasons for judgment of the

Dubé, J:—The main issue to be determined in this case is whether the plaintiff corporation in its fiscal year ending November 30, 1975 was associated with Fawcett Enterprises Limited and Son Valley Ranch Limited under paragraph 256(1)(b) of the

Walsh, J:—This is an appeal from a decision of the Tax Review Board dated February 25, 1977 referring defendant’s assessments for his 1971 and 1972 taxation years back to the Minister of National Revenue for reconsideration and reassessment. The Minister

Pratte, J:—This is an appeal from a judgment of the Trial Division ordering the appellant to pay the respondent the sum of $587,769.63 together with the penalty prescribed by subsection 50(4) of the Excise Tax Act and the costs of the

Le Dain, J:—The facts and the issues have been fully set out and very carefully analysed in the reasons of my brother Ryan. I agree with him that, as the appeal was argued, the central issue is whether what was provided for by

Keith, J:—In my judgment this appeal must fail and since the entire argument has been taken down by the Court Reporter, it is unnecessary for me to deliver elaborate reasons.

MacPherson, J:—The Board of Revenue Commissioners achieved a certain amount of unjustified notoriety for appearing to hold in this matter that an aeroplane is a tractor and therefore exempt from provincial sales tax. The Minister, being dubious, appealed to this Court.