Sarchuk, T.C.J.:—The appellants John S.M. Chan (Chan), Jamie Ung (Ung) and Ellen Ung appeal from reassessments of income tax in respect of their 1980 taxation year. The three appeals were heard at the same time on common evidence. The issue is

Tremblay, T.C.J.:—This appeal was heard on December 4, 1986 at the City of Ottawa, Ontario.

Rip, T.C.J.:—This is an appeal from a notice of assessment for the 1980 taxation year in which the Minister of National Revenue, Taxation, the respondent, assessed The Estate of Jeannette Bell Kelley, referred to in the pleadings as the appellant, income

Sarchuk, T.C.J.:—Edward Laurence (Laurence) appeals from reassessments to tax for his 1978, 1979, 1980 and 1981 taxation years.

Sarchuk, T.C.J.:—Yorkton Broadcasting Company Limited (Yorkton) appeals from reassessments of income tax with respect to its 1978 to 1981 taxation years. The appellant is a corporation which during these years carried on the business of operating a radio and

Taylor, T.C.J.:—These are appeals against income tax assessments for the years 1980 and 1982, heard on common evidence in Fredericton, New Brunswick, on August 13 and 14, 1986 and continued on January 8, 1987. I will use the 1980 notice of appeal

Goetz, T.C.J.:—This is an appeal from a tax reassessment for the appel lant’s 1983 taxation year, whereby certain interest income accruing from a tax refund was allocated to the Canadian resident beneficiaries and none of it to a non-resident beneficiary.

Couture, C.J.T.C.:—This is an appeal against assessments issued by the respondent on the 6th of October 1983 for the taxation years 1980 and 1981.

Christie, A.C.J.T.C.:—This appeal relates to the appellant's 1980 taxation year. The question to be answered is whether the gain realized on the sale of a townhouse in the municipality of Oak Bay in the greater Victoria area (“the property") is a

Bonner, T.C.J.:—The appellant, as successor to Mattagami Lake Mines Limited (hereinafter “Mattagami”), appeals from assessments of income tax for Mattagami’s 1977 and 1978 taxation years. During those years Mattagami was engaged in developing a mine at Lyon Lake,