Grant, DJ:—This is an appeal from the decision of the Tax Review Board dated April 21, 1978, whereby the plaintiff’s appeals from the reassessment of his income tax returns by the Minister of National Revenue for the years 1971 and 1972 were

Mahoney, J:—The issue is whether payments made by the plaintiff to an independent contractor fall within the definition of “cost of labour’’ under section 5202 of the Income Tax Regulations. The plaintiff included the payments in computing the amount of

Gibson, J:—For the reasons given in the case of MDS Health Group Limited (Toronto Medical Laboratories Limited) v Her Majesty The Queen (Court No T-4587-77) this date, this appeal is

Gibson, J:—For the reasons given in the case of MDS Health Group Limited (Toronto Medical Laboratories Limited) v Her Majesty The Queen (Court No T-4587-77) this date, this appeal is

Gibson, J:—For the reasons given in the case of MDS Health Group Limited (Toronto Medical Laboratories Limited) v Her Majesty The Queen (Court No. T-4587-77) this date, this appeal is

Gibson J:—For the reasons given in the case of MDS Health Group Limited (Toronto Medical Laboratories Limited) v Her Majesty The Queen (Court No. T-4587-77) this date, this appeal is

The Chairman:—The appeal of John Donald Irwin is from assessments by which the Minister of National Revenue disallowed ‘the deductions of life insurance premiums in the amount of $1,880.50 for the 1973 taxation year and in the amount of $1,460.50 for

Guy Tremblay:—This case was heard at Halifax, Nova Scotia, on June 12, 1978.

Guy Tremblay:—The present case was heard at Montreal, Quebec, on May 11, 1978.

Guy Tremblay:—This case was heard at Montreal, Quebec, on November 6, 1978.