Guy Tremblay:— This case was heard on April 30, 1982, at the City of London, Ontario and was completed on May 25, 1982, at the City of Toronto, Ontario.

Guy Tremblay [TRANSLATION]:—This appeal was heard June 17, 1982, in the City of Montreal (Quebec).

D C Taylor [TRANSLATION]:—This appeal, heard on November 15, 1982 in the City of Montreal, Quebec, is from a tax assessment for 1977 in which the Minister of National Revenue added the sum of $45,891.86 to the income reported by the

Guy Tremblay [TRANSLATION]:—This appeal was heard January 10, 1983, in the City of Montreal (Quebec).

The Chairman:—The appeals of Victor and Jean Gusso are from assessments with respect to the 1978 taxation year. The appeals were decided on the basis of common evidence given by Victor Gusso.

The Chairman:—In his tax return for the 1978 and 1979 taxation years the appellant claimed restricted farm losses in the amount of $4,400 and $5,000 respectively in accordance with section 31 of the Income Tax Act, SC 1970-

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