THURLOW, J.:—This is an appeal from re-assessments of income tax for each of the years 1957 to 1963 inclusive. The main issue, which is the same in respect of each of the years in question, is whether, or to what extent, amounts which the Minister treated as profits earned by the appellant in Canada are subject to tax having regard to Section 10(1) (c)*[1] of the Income Tax Act, R.S.C. 1952, c.

JACKETT, P.:—This is a Petition of Right by the Executors of the Estate of Rachel McM. M. Hunt seeking a determination that a writ of fiert facias issued out of this Court did not attach certain shares of Aluminium Limited belonging to

SHEPPARD, D.J.:—The appeal is by the British Columbia Power Corporation, Ltd. (called B.C. Power) against an assessment by the Minister of National Revenue; a cross-appeal by the Minister has been withdrawn.

SHEPPARD, D.J.:—Dealing with the motion to strike out paragraphs 14, 15 and 19 of the Minister’s reply the ground is raised that the Minister has no right or jurisdiction to appeal against assessment by the Minister. I observe that Section 98, which is the initial section under Division J, or 98(1) in particular, deals with appeals to the Exchequer Court by either the taxpayer or the Minister and the latter part of the section reads :

‘‘And if the appeal is from the Tax Appeal Board.”

THURLOW, J.:—The issue in this appeal, which is from reassessments of income tax for the years 1963 and 1964, is whether the appellant and Esson Motors Limited were, in the taxation years in question, ""associated with each other’’ for the purpose of

DUMOULIN, J.:—Dr. James Sim, a member of the Royal College of Dental Surgeons, practises his profession in the City of St. Catharines, Ontario, where he permanently maintains an office with a staff of three employees.

SHEPPARD, D.J.:—This appeal is by Charles Glassman from the assessment by the Minister of National Revenue for the taxation year 1959 in refusing any allowance based on the capital cost of buildings and equipment on Lot 7, Block 63, DL 185, being

CATTANACH, J.:—These are appeals against assessments by the Minister under the Income Tax Act of the appellant for its 1961, 1962 and 1963 taxation years.

By agreement the evidence respecting these appeals was heard immediately following the evidence with respect to the appeals of Alpine Drywall Construction Limited, upon completion of which argument was heard on each set of appeals because the issues involved in each set of appeals were substantially the same, subject only to minor variations consequent upon minor differences in facts.

CATTANACH, J.:—These are appeals from the assessments of the appellant under the Income Tax Act, R.S.C. 1952, e. 148 for its taxation years 1961, 1962 and 1963.

GIBSON, J.:—By its Petition of Right the suppliant, a company incorporated under the Ontario Corporations Act, with head office in the City of Toronto, seeks to recover certain moneys paid by it under protest pursuant to a Notice of Assessment