Bergeron, J:—This Court is seized with an appeal by the Crown, under Part XXIV of the Criminal Code, from a judgment rendered on December 14, 1982, by the Court of the Sessions of the Peace of Montreal, acquitting respondents of

Muldoon, J:—This is an appeal from a decision of the Tax Review Board delivered on May 20, 1981. The parties filed a statement of agreed facts, which, with a few corrections mentioned by counsel now incorporated in it, and some abridgement, is recited below.

Muldoon, J:—This case involves a dispute between the plaintiff and the Minister of National Revenue concerning sums of money paid, and charitable deductions claimed, by the plaintiff to three non-profit corporations, all incorporated under the laws of Ontario, which

Rouleau, J:—The issue in this trial is directed to the Valuation-Day appraisal (V-Day December 31, 1971) placed on a nine-storey office complex located at 245 Victoria Avenue in the city of Montreal. The property was owned by a corporate body known as 245

Muldoon, J:—The three brothers Rudolph were in the construction business in Winnipeg, Manitoba. The brothers, Ernest (now deceased), Leopold and Walter caused the plaintiff, W Rudolph Construction Ltd to be incorporated in 1960 as their vehicle of business. Ernest

Muldoon, J:—The court is here adjudicating upon two actions, by way of stated cases pursuant to Rule 475, with the same plaintiff and defendant in each action. Thus, the first paragraph is identical in both stated cases:

Rouleau, J:—This is an application of a special case for the specific purpose of deciding two questions:

Rouleau, J:—The issue in this case is whether or not the applicant may apply to the Trial Division of the Federal Court under section 18 for an order quashing assessments made against him and thereby restraining the Minister and his servants from taking further

Cattanach, J:—These are three appeals from decisions of the learned member of the Tax Review Board, as he was at that time, involving the assessments to income tax directed to the three plaintiffs herein by the Minister of National Revenue.

Collier, J:—This is an appeal by the plaintiff against an income tax assessment for its 1975 taxation year.