The Chairman:—The appeal of Scandia Plate Ltd is from an assessment whereby the Minister of National Revenue disallowed a small business deduction under subsection 125(1) of the Income Tax Act on the ground that the appellant was

M J Bonner:—This is an appeal from an assessment of income tax for the 1978 taxation year. On assessment the respondent included in income certain service contract revenue received during the year. The appellant, in its domestic financial statements,

M J Bonner:—This is an appeal from an assessment of income tax for the appellant’s 1978 taxation year. The events giving rise to the assessment are somewhat unusual. The appellant had borrowed money from its bank, the Bank of Montreal. On

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.