M J Bonner:—Two unrelated issues arise in appeals from assessments of income tax for the appellant’s 1977, 1978 and 1979 taxation years.

M J Bonner:—The appellant’s daughter was, under the terms of a will which created a trust, entitled to receive certain income. Part of that income found its way into the appellant’s hands as a result of a contract made between the

The Chairman:—The appeals of the Estate of Edward Earl Walsh, Howard J Riopelle, John B Ebbs, QC and Mathias P Jensen, from assessments with respect to the 1976 taxation year, were heard simultaneously and the decision in each appeal is being

D E Taylor:—These are appeals heard on common evidence on October 20, 1982, in the City of Victoria, British Columbia. The point at issue in each appeal is exactly the same — the disallowance by the Minister of National Revenue of a

Guy Tremblay:—This case was heard on November 3 and 4, 1981, at the City of Halifax, Nova Scotia.

Guy Taylor:—These appeals were heard on common evidence on November 4, 1982, at the City of London, Ontario.

Guy Tremblay [TRANSLATION]:—This case was heard in Quebec City, Quebec on October 12, 1982.

Guy Tremblay:—This appeal was heard on June 15, 1982, at the City of Montreal, Quebec.

D E Taylor [ORALLY]:—These are the appeals of Northwest Wood Preservers Ltd for the taxation years 1975, 1976 and 1977. While there are different amounts of tax at issue in the various years, the issue is the same and will be dealt

M J Bonner:—The appellant appeals from assessments of income tax for the 1972 and 1974 taxation years. On assessment the respondent treated as income part of the gain realized on the sale: