Mahoney, J:—The issue is whether, upon conversion in 1977 of a debenture purchased from his employer in 1972, the plaintiff received a taxable benefit in the amount of $6,577.25, being the difference between the value of the shares acquired on conversion

Grant, DJ:—The plaintiff is a company that carried on business as a manufacturer and fabricator of metal forgings, castings and other metal products for some time prior to December 31, 1976. Two of the principal management employees of the plaintiff were

Mahoney, J:—This is a special case stated pursuant to Rule 475. The subject is issue estoppel. The questions to be answered are:

Urie, J:—This is an appeal from a judgment of the Trial Division dismissing an appeal from a decision of the Tax Review Board. The appellant had appealed an income tax assessment made by the Minister of National Revenue which had added to the

Carrothers, D J:—I will ask my brother Macfarlane to give the first judgment.

Collier, J:—These reasons are given in this action (T-2445/80: Campbell v The Queen). They will apply in action T-2444/80: Smith v The Queen. The two actions were tried on, where applicable, common

Décary, J:—In this matter, the facts were agreed upon:

Mahoney, J:—The defendant was a Canadian resident, employed by a Canadian corporation Tranter Canada Ltd, a wholly owned subsidiary of Tranter, inc [sic], hereafter “Tranter”, a Michigan corporation. On January 28, 1976, Tranter granted the defendant an option to

Mahoney, J:—The plaintiff acquired a block of 59.3 acres of land on the southerly extremity of the City of Edmonton on November 27, 1961, at a price of $4,000 per acre. Certain of the land was expropriated after acquisition. On February 1,

Mahoney, J:—The first issue is whether a “portable” asphalt plant, acquired by the plaintiff in its 1974 taxation year and first used in its 1975 taxation year, generated “Canadian manufacturing and processing profits” for purposes of subsection 125.1(1) of