M J Bonner:—This is an appeal from an assessment of income tax for the appellant’s 1977 taxation year ending July 31, 1977. The appellant at all relevant times carried on the business of a franchisor of take-out chicken stores. In the

The Chairman:—The appeal of Ernest Bouchard is from an assessement with respect to the 1976 and 1977 taxation years.

There are two separate issues arising from the Minister’s assessment:

The Chairman:—The appeals of Anne H Sigglekow are from assessments with respect to her 1975, 1976 and 1977 taxation years.

The facts are not in dispute and are set out in the appellant’s statement of facts:

Guy Tremblay:—This case was heard on February 12, 1981, in Winnipeg, Manitoba.

Guy Tremblay:—This case was heard in the City of Winnipeg, Manitoba on February 9, 1981.

Guy Tremblay:—These cases were heard in Edmonton, Alberta, on June 2, 1981.

Guy Tremblay:—This case was heard in Toronto, Ontario, on September 30, 1980. It was taken under advisement after the filing of the last written submissions on November 26, 1980.

Guy Tremblay:—This case was heard in Montreal, Quebec, on March 12 and 13, 1980. Following the written submissions, the case was taken under advisement on November 7, 1980.

Guy Tremblay:— This case was heard in Winnipeg, Manitoba, on February 12, 1981.

Taylor, D E:—This application was heard at Toronto, Ontario, on September 21, 1981. The full text of both the Application itself, and the Minister’s “Reasons for Opposing Application” are provided for the record: