The Chairman:—The appeal of 86103 Ontario Incorporated, is from an assessment with respect to the 1975 taxation year. In issue is the fair market value of the appellant’s land and building as at December 31, 1971.

Guy Tremblay:—This case was heard in Edmonton, Alberta, on March 1, 1982.

Guy Tremblay:—This case was heard in Edmonton, Alberta, on March 1, 1982.

John B Goetz:—This is an appeal with respect to the appellant’s 1974 taxation year.

The issue before me is to determine who held the beneficial ownership of certain farmland.

The Assistant Chairman:—These two cases were called for hearing at 9:30 am on July 6, 1982, at Toronto, Ontario. Because of the judgments which were given that day, it is considered best to write short reasons. The Notices of Appeal were

Roland St-Onge:—The appeals of Fred Berman, Susan Lovik (formerly Susan Berman) and Sophie Harris came before me on June 4, 1982, in the City of Vancouver, British Columbia and it was agreed between the parties that the appeals be heard on common

Guy Tremblay (TRANSLATION):—This case was heard at Montreal, Quebec on March 30, 1982.

Guy Tremblay [TRANSLATION]:—These cases were heard on common evidence at Montreal, Quebec on September 25, 1981.

M J Bonner [Orally]:—This is an appeal from the assessment of income tax for the 1979 taxation year.

D E Taylor:—This is an appeal heard in Montreal, Quebec, on May 5, 1982 against an income tax assessment for the year 1979 in which the Minister of National Revenue disallowed an amount claimed by the appellant pursuant to the provisions