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:

The Chairman (orally: December 11, 1974):

1 This is an appeal by John T Burnett against the reassessment of the Minister of National Revenue for the 1971 taxation year. The point at issue is the nature of a total sum of $10,000 which, it is alleged by the appellant, consisted of $7,000 received by him for his interests in a company known as Aegis Marketing International Limited and $3,000 for expenses incurred by him over the course of his association with the company.

Collier, J:

Judson, J (per curiam):

Roland St-Onge:

1 This appeal is from a reassessment dated June 21, 1974 with respect to the appellants' 1973 taxation year. It came before me on June 16, 1975 in the City of London, Ontario.

• (1) Two of the executors and trustees of this estate, Fitz James Bridges and Margery Lee Bridges, are residents of Mount Clemens, Michigan, USA, and the third executor and trustee, R Robert Easton, is resident in Ontario.

Collier, J:

1 This appeal was heard on common evidence with the appeal of Antoine Hulmann v. The Queen (p 297). The reasons given in the latter case shall apply in this case.

2 The appeal is accordingly dismissed. The reassessments by the Minister of National Revenue for the years 1966 through 1969 are confirmed. The respondent is entitled to costs.

Cattanach, J:

1 These are appeals from a decision by the Tax Review Board whereby the appeals by the defendant herein to that Board from assessments by the Minister of National Revenue for the 1970 and 1971 taxation years were allowed.

2 The assessments by the Minister were consequent upon the sale of three properties by the defendant, two of which were situate in the City of Calgary, Alberta, and the third was situate in the City of Edmonton, Alberta.