Urie, J:—I have had the advantage of reading the reasons for judgment of Mr Justice Ryan. While I find them persuasive, after the most careful consideration I have concluded, with regret, that I am unable to agree with them and, consequently, with

Culliton, D J:—This is an appeal from the judgment of Grant, D J dismissing the appellant’s action in which it sought a declaration that it was entitled to deduct capital cost allowance in respect to the buildings on the land at 119-129

Addy, J:—These two appeals, which were heard at the same time on common evidence, involve the taxability during taxation years 1971, 1972 and 1973 of the income of the plaintiff Gurd’s Products Company Limited (hereinafter referred to as “Products”) and

Gibson, J:—This is an appeal of Supreme Theatres Limited from assessments of tax of its 1972 and 1973 taxation years, notices of which are dated February 9, 1978.

Marceau, J:—In filing his tax return for the 1976 taxation year, relying on sections 3 and 9, on paragraph 18(1 )(a) and on section 111 of the Income Tax Act (SC 1970-71-72, c 63, as amended), the plaintiff claimed a deduction

Cattanach, J:—This is an appeal from a decision of the Tax Review Board whereby a penalty in the amount of $6,844.92 imposed by the Minister of National Revenue upon the defendant for its 1973 taxation year pursuant to subsection 163(2) of the

The Associate Chief Justice:—The facts in this case are neither complicated nor unique and they formed the subject of an agreed statement of facts by counsel as follows:

Urie, J:—This is an appeal from a judgment of the Trial Division whereby the appellant’s appeal from reassessments for income tax made by the Minister of National Revenue (hereinafter referred to as “the Minister”) for the taxation years 1966, 1967 and

Heald, J:—This is an appeal from a judgment of the Trial Division which allowed the respondent’s appeal from a reassessment for income tax in respect of the respondent’s 1972 fiscal year which ended on October 31, 1972. The Trial Division judgment

Mahoney, J:—The plaintiff appeals the decision of the Tax Review Board [1978] CTC 3130; 78 DTC 1787, that upheld disallowance of two outlays as expenses: (1) a $20,000 payment in 1969 to obtain releases from commitments and (2) a series of payments