Urie, J:—This is an appeal from a judgment of the Trial Division dismissing the appellant’s actions with respect to income tax reassessments made by the Minister of National Revenue in respect of the appellant’s 1973, 1974, 1975 and 1976 taxation years.

Smith, DJ:—The issues in these two cases are the same, save for differences in the amounts of money involved. It was agreed by the parties that the two cases be heard together and that the evidence given to the Court apply equally to

Gibson, J:—This appeal relates to the 1975, 1976, and 1977 taxation years of Timagami.

Pratte, J:—It is unnecessary for the purposes of this appeal to decide whether the decision of the Supreme Court of Canada in F Sura v MNR, [1962] CTC 1; 62 DTC 1005, must still be followed despite the changes that

Cattanach, J:—By notice dated April 30, 1976 the Minister of National Revenue reassessed the plaintiff by including in its income an amount of $652,976.37 for its 1973 taxation year.

Cattanach, J:—This is an appeal by the plaintiff from an assessment to income tax made by the Minister of National Revenue for the plaintiff’s 1976 taxation year.

Gibson, J:—The five plaintiff corporations other than Honeywood Limited appeal from assessments for income tax in respect to their respective taxation years 1968 and 1969 and Honeywood Limited appeals from an assessment for income tax for its taxation year

Gibson, J:—This is an appeal from a reassessment for income tax for the taxation year of 1973 of Farquhar Bethune Insurance Limited.

Urie, J:— This is an appeal from a judgment of the Trial Division vacating assessments made by the Minister of National Revenue which required payment of tax and penalties for the 1975, 1976 and 1977 taxation years. These assessments arose as

Urie, J:—This is a section 28 application to review and set aside a decision of the respondent made pursuant to the Excise Tax Act, RSC (1970) c E-13 (hereinafter called “the Act”), wherein he held that two publications,