D E Taylor:—This is an appeal heard in Vancouver, British Columbia, on January 17, 1983, against an income tax assessment for the year 1978 in which the Minister of National Revenue rejected the appellant’s claim for an amount of $5,518.55 as

D E Taylor:—This is an appeal heard in Montreal, Quebec, on December 6, 1982, against an income tax assessment for the year 1979 in which the Minister of National Revenue demanded remittance of the 15% non-resident tax under the Income

Guy Tremblay:—The evidence of this case was heard in Montreal, Quebec, on January 14 and 15, 1982. The argumentation was heard in Ottawa, Ontario, on February 11, 1982.

John B Goetz:—This is an appeal with respect to the appellant’s 1978 taxation year. The issue is whether the sale, in 1978, of a building, hereinafter referred to as “Tower A”, owned by the appellant, was on capital account or on income

Guy Tremblay:—This case was heard on July 14, 1982, at the City of St John’s, Newfoundland.

Guy Tremblay:—This appeal was heard on May 25, 1982, in the City of Toronto, Ontario.

Guy Tremblay:—This case was heard on April 28, 1982, at the City of London, Ontario.

D E Taylor:—This is an appeal heard in Montreal, Quebec on November 19, 1982, against an income tax assessment for the year 1977 in which the Minister of National Revenue refused to allow a deduction of $3,123.45 claimed by the appellant

D E Taylor [TRANSLATION]:—This is the appeal of Produits d’Acier Phoenix Ltée for 1975, 1976 and 1977.

The appeal is vacated for 1976.

M J Bonner:—The appellant appeals from assessments of income tax for the 1974 to 1977 taxation years. On assessment the respondent included in the computation of income: