The Assistant Chairman:—Both Mr Shell and Mr Horta have appealed to this Board from assessments of income tax for their 1974 taxation years.

John B Goetz:—The appellants’ appeal relates to the 1976 taxation year. Counsel for the appellants and for the respondent filed an Agreed Statement of Facts, which reads as follows, and appended thereto was the last will and testament of Gray

John B Goetz:— This is an appeal by Luigi Borrelli with respect to his 1977 taxation year. It was agreed that the appeal of Frank Borrelli, brother to the appellant, would be heard on common evidence.

John B Goetz:—This is an appeal by the appellant with respect to its 1977 and 1978 taxation years whereby, pursuant to the provisions of paragraph 20(1 )(gg) of the Income Tax Act, SC 1970-71-72, c. 63, as amended, (said

John B Goetz:—It is not for me to comment on the intention of Parliament in wording subsection 62(1) of the Income Tax Act, SC 1970-71-72, c 63, as amended, that way. Mr Erlichman well knows that on occasion l felt

John B Goetz:—This is an appeal by Carson Camps Ltd with respect to its 1975 taxation year. Carson Camps Ltd is a wholly-owned company of one Irwin Carson, a practising lawyer at the time of incorporation. Mr Carson indicates in his

Guy Tremblay [TRANSLATION]:—This case was heard at Montreal, Quebec on May 15, 1981.

Roland St-Onge [TRANSLATION]:—The appeal of Cabana, Séguin Inc came before me on March 3, 1981 in the city of Montreal, Province of Quebec.

The Chairman [TRANSLATION]:—The appeal of Mr André Lalonde is from reassessments by which the respondent disallowed deduction of the expenses claimed by the appellant as business expenses, amounting to $11,036.55, $13,457.96, $11,965.21 and $1,801.76 for the taxation

Guy Tremblay:— This case was heard in Toronto, Ontario, on December 2, 1981.