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 September 28, 1982, at the City of Ottawa, Ontario.

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

D E Taylor:—This is an appeal heard in Toronto, Ontario, on September 23, 1982, against an income tax assessment for the year 1976 in which the Minister of National Revenue established the fair market value of a certain parcel of real

D E Taylor:—These appeals, heard on July 8, 1982 in Charlottetown, Prince Edward Island, are against income tax assessments for the years 1978 and 1979 in the case of Mr Hall, and for the years 1978, 1979 and 1980 in the case of

M J Bonner [ORALLY]:—The appellant appeals from assessments of income tax for the 1975, 1976 and 1977 taxation years. As to the assessment for 1977, the appellant concedes that it is correct and consents to judgment dismissing the appeal therefrom.

Grant, DJ:—The plaintiff is a corporation incorporated under the laws of Canada. Pursuant to an agreement dated February 19, 1981 (Tab 5 in group of documents filed by the plaintiff) it took over from its parent corporation, Fiat Motors of North

Walsh, J:—This action was heard jointly on the same proof as that of Jean- Paul Demers v The Queen, No T-2897-82 with the proof being made in this record. Both actions concern capital gain assessments for the 1976,

Collier, J:—This is an appeal from a decision of the Tax Review Board.

Le Juge Marceau:—J’ai eu l’occasion de lire les notes de mon collègue, le juge Hugessen, et malheureusement je suis incapable de souscrire à sa façon de voir. Aussi, me permetterai-je, avec respect, de faire valoir une opinion contraire à la