Teitelbaum, J.:—By means of a direct action in the Federal Court of Canada, Trial Division, the plaintiff is contesting the reassessment made by the Minister of National Revenue. The said reassessment, dated April 7, 1982, added the sum of $50,000 to

McNair, ).:—This is an appeal by way of action pursuant to section 172 of the Income Tax Act from a notice of reassessment dated November 4, 1982 in respect of the plaintiff's 1981 taxation year. The reassessment was

Mahoney, J.:—These are three appeals and cross appeals from judgments of the Trial Division, [1984] C.T.C. 387; 84 D.T.C. 6374, respecting the re- spondent's income tax assessments for its 1975, 1976 and 1977 taxation years. The respondent concedes that the

Mahoney, J.:—We are in substantial agreement with the reasons for judgment of the learned trial judge herein and would dismiss the appeal with costs. In our opinion, where the business of a taxpayer is the sale of franchises to others, the proceeds

Marceau J.:—We are all of the view that this appeal is well founded. The learned motions judge was wrong in granting the respondents' application for review of the taxation of the appellants’ costs under Rule 346 of the General Rules

McNair, J.:—This is an appeal by the plaintiff from the Minister's reassessments with respect to the 1976, 1977 and 1978 taxation years whereby portions of reserves claimed by the plaintiff were disallowed and added back into income. Three statements of

Cumming, J. [Orally]:—The appellant, the Attorney General of Canada, on behalf of Her Majesty The Queen in right of Canada, appeals pursuant to Bankruptcy Rule 108 and section 106 of the Bankruptcy Act from the disallowance on May 7,

Pinard, J.:—This is a motion dated the 8th day of May, 1986 on behalf of the plaintiff for “an Order pursuant to sections 18 and 44 of the Federal Court Act, quashing the seizure of the ship ‘Orion Expeditor" and returning

The Associate Chief Justice:—This matter, dealing with the interpretation and application of paragraph 40(1)(a) of the Income Tax Act came on for hearing at London, Ontario on December 10, 1985.

Pratte, J.:—Ms. Lloyd and Ms. Burns, we do not need to hear you. We are all of opinion that this appeal must fail.