Lacroix, DJ:

1 The plaintiff, an employee of the Government of the Province of Quebec, Department of Revenue, alleges that he filed his income tax return for the taxation year 1971, and that on June 21, 1972 the Deputy Minister of National Revenue issued a notice of assessment, No 43738928, based on the sum of $16,268 instead of the plaintiff's estimate of $14,639.85.

A J Frost:

1 This is an appeal from income tax assessments dated April 13, 1973 in respect of appellant's 1968, 1969, 1970 and 1971 taxation years.

O'Connor T.C.J.:

Collier, J:

Dubé, J:

1 The Minister of National Revenue has appealed from the allowance by the Tax Appeal Board of appeals of Malloney's Studio Limited from assessments to income tax in respect of its 1966 and 1967 taxation years which ended on May 31 in each year.

2 For convenience of reference, the Minister of National Revenue and Malloney's Studio Limited shall hereinafter be referred to respectively as “the Minister” and “the Company”.

The Chairman (orally: December 12, 1974):

A J Frost:

The Chairman (orally: March 19, 1975):

1 This is an appeal by Polly Chersky Smith, Marvin Smith, Eric Morton Smith, Dame Jacqueline Smith (wife of Arthur Freedman), and Harold Margolese, executors under the will of Manasseh Smith.

The Chairman (orally: December 13, 1974):

1 This is an appeal by Doral Investment Corporation against reassessments of the Minister of National Revenue for the 1970 and 1971 taxation years. The point at issue is whether or not a loss claimed by the appellant in the amount of $175,000, approximately, is deductible in the year 1970 or whether it is really a repayment, or the result of a repayment, of capital to this company by or on behalf of Mr Max Schuchmann.

Walsh, J: