D E Taylor:—These are appeals heard on common evidence in Montreal, Quebec, on May 4, 1982 against income tax assessments for the year 1975 in which the Minister of National Revenue added to each of the taxable incomes of the appellants

D E Taylor:—This is an appeal heard in Calgary, Alberta, on March 10, 1982 in connection with income tax assessments for the years 1977 and 1978. The Notice of Appeal reads in part as follows:

Roland St-Onge:—The appeal of Happy Valley Farms Ltd came before me on June 2, 1982 In Vancouver, British Columbia, and it concerns a real estate transaction with respect to the 1977 taxation year.

D E Taylor:—These are appeals from King Lee and Bic Lee, husband and wife, with respect to additional funds added by the Minister of National Revenue to their incomes for the years 1973, 1974 and 1975. In the assessments at issue, the

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