Le Dain, J:—This is an appeal from a judgment of the Trial Division allowing an appeal from a decision of the Tax Review Board, which allowed an appeal from a reassessment of income tax in respect of the appellant’s 1976 taxation year by which an

Gibson, J:—The evidence in this appeal consisted of an Agreed Statement of Facts, Exhibit 29, and documentary evidence, Exhibits 1-28 and 30- 34, and the oral evidence of Mr Morry Wingold, which evidence was substantially different than the evidence adduced

Urie, J:—The appellant appeals from the judgment of the Trial Division upholding the reassessment of the Minister whereby part of the proceeds arising from the expropriation of property in which the taxpayer had the equitable interest was assessed as profits

Gibson, J:—This action and six other actions were tried on common evidence, namely, actions T-4034-76, T-4035-76, T-4037-76, T-4038-76, T-4047- 76, T-4048-76.

Gibson, J:—B & J Music Limited (formerly Buegeleisen & Jacobson Limited) until 24 June 1974 was controlled by non-residents of Canada namely by residents of the United States. On that day it became a Canadian-controlled private corporation.

Walsh, J:—This action arises out of the seizure in the hands of plaintiff companies of certain assets allegedly belonging to them for income tax and other tax arrears owed by one Kenneth Richard Allen and a company owned and operated by him

Heald, J:—This is an appeal from a judgment of the Trial Division allowing the respondent’s appeal from a decision of the Tax Review Board in respect of reassessments issued by the Minister of National Revenue in respect of the appellant’s 1968

Marceau, J, [TRANSLATION]:—Toward the end of 1974, shortly after he had retired as a federal government employee, the defendant applied for and obtained employment with the Organization of American States (OAS). The employment was intended to be for a one-year

Heald, DJ:—This is an appeal from two judgments of the Trial Division, allowing appeals in respect of income tax reassessments for the years 1964 to 1967 inclusive, (Appeal A-68-81) and 1969 to 1972 inclusive (Appeal A-67- 81). The two matters were

J Walsh, J:—Plaintiff, pleading his own case contests the income tax assessment of his father the late George Pappas for the 1976 tax year during which the said George Pappas died on November 9, 1976, as a result of which plaintiff