Dubé, J:—The plaintiff, a resident of Switzerland, appeals the assessments for his 1971 and 1972 taxation years including the total sums of $1,116,712.10 and $934,691.04 respectively as income from a “money lending business carried on by him in Canada”.

Thurlow, CJ:—The issue in this appeal is whether the taxable income of the respondent for the taxation years 1972, 1973, and 1974, when the respondent did not qualify for a tax deduction as a Canadian controlled private corporation, must be brought

Jerome, ACJ:—This is an action by way of appeal from a decision of the Tax Review Board, made at Edmonton, Alberta, on May 29, 1980. I heard evidence and submissions of counsel at Edmonton on May 28, 1982 and held the matter under

Dubé, J:—The main issue to be resolved here is whether the sale of the plaintiff's property to one Jack Mendlewitz took place on October 29, 1968 as alleged by the plaintiff, or on September 10, 1970 as assumed by the Minister, and therefore

Heald, J:—This is an appeal from an interlocutory judgment of the Trial Division which:

Heald, J:—Rule 447(2) required the respondent to file and serve on the appellant a list of documents specified therein within 20 days after the pleadings in the action were deemed to be closed. It is common ground that this was not done on a timely

Marceau, J:—This action is brought against notices of reassessment issued by the Minister of National Revenue in respect of the plaintiff’s 1975, 1976 and 1977 taxation years. The question raised is that of the market value, on December 31, 1971

Le Dain, J:—This is an appeal from a judgment of the Trial Division allowing an appeal from a decision of the Tax Review Board with respect to a reassessment for the 1962, 1963, 1966 and 1967 taxation years.

Walsh, J:—Plaintiff moves pursuant to Rule 324 for an order extending the time to make the application and for the Court to make a special direction concerning costs to the effect that the action be considered as a Class III action within the

Le Dain, J:—This is an appeal from a judgment of the Trial Division dismissing the appellant’s appeal from income tax assessments in respect of his 1975 and 1976 taxation years.