Gibson, J:—Controlled Foods Corporation Limited operates restaurants in the Provinces of British Columbia, Alberta, Saskatchewan and Ontario and so the same issue as arises in this appeal would arise in respect of all their restaurants.

Gibson, J:—Farmparts Distributing Ltd of Saskatchewan, Canada by notices of assessment for income tax dated November 26, 1976 and April 29, 1976 was levied tax equivalent to 15% of two amounts paid by it to Wonder International Limited of New Jersey,

Pratte, J:—Counsel for the appellant attacked the judgment of the Trial Division on two grounds.

Zalev, CCJ:—Subsection 231(3) of the Income Tax Act provides as follows:

Anderson, J:—This is an appeal from the decision of the Minister of Finance that a debt owing by the estate of the deceased to one Lucie Johnston did not constitute a debt of the estate for the purposes of the Succession Duty

Collier, J:—This is a taxpayer’s appeal against an assessment, made by the Minister of National Revenue, under the Income Tax Act.

The parties filed a statement of agreed facts. I set it out in full:

Pratte, J [TRANSLATION]:—Appellant is appealing from the decision of the Court of Appeal of the province of Quebec which, affirming the judgment of the Superior Court (Bélanger, J), ruled that the sum of $125,000 due by the Life Insurance Company of

The Chief Justice:—This is a section 28 application to set aside a decision of The Minister of National Revenue that certain publications to wit:

(a) Rapid Auto Mart Magazine,

Le Dain, J:—We are all of the view that the appeal must be dismissed on the ground that the tax imposed on the appellant under the Income Tax Act, RSC 1952, c 148, is not taxation in respect of personal property

Walsh, J:—This section concerns the assessments of defendant for its 1970 and 1971 taxation year in which plaintiff disallowed the deduction claimed by defendant of the amounts of $23,988 and $19,357 respectively for realty taxes paid to the City of