D E Taylor:—This is an appeal heard in Toronto, Ontario, on April 5, 1982 against income tax assessments for the years 1974, 1975 and 1976. In assessing the appellant, the Minister of National Revenue relied, inter alia, upon

Roland St-Onge [TRANSLATION]:—The appeal of Mr Patrice Roy and his company Patrice Roy Inc and of Galerie du Meuble Lanctot Inc came before me on February 16 and November 3, 1981, in the city of Sherbrooke, province of Quebec: it involves

The Assistant Chairman:—In 1975 Northern Garage and Holdings Ltd (the appellant) sold a parcel of land situate in the City of Ottawa which it had owned for many years. The parcel was described municipally as #1025 Richmond Road and was located

The Chairman [TRANSLATION]:—The appeals of Mr Giovanni Marinelli are from assessments for the taxation years, 1972 to 1976 inclusive, in which the respondent added to the taxpayer’s income certain amounts that had not been included in the appellant’s

Roland St-Onge [Translation]:—The appeal of Laurentide Rendering Inc was heard before me on January 22, 1981, in the city of Montreal, Quebec, and comprises two issues arising out of an expropriation of the appellant’s business that took place during

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