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

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