Walsh, J:

The Chairman (orally: March 19, 1975):

Roberts, J:

Collier, J (orally):

1 This is an appeal on behalf of the Minister of National Revenue from a decision of the Tax Review Board. The facts before the Board are the same as those before this Court. They are set out in an agreed statement (Exhibit 1).

The Chairman (orally: February 12, 1975):

1 This is an appeal by Desmond M Connor against the reassessment of the Minister of National Revenue for the 1969, 1970 and 1971 taxation years.

Roland St-Onge:

1 This appeal is from a reassessment dated May 10, 1973 with respect to the 1968 taxation year.

2 The appeal came before me on January 30, 1975 at the City of Ottawa, Ontario. At the hearing the parties agreed that the evidence and arguments in the present appeal would also apply to the appeals of Saul Leese, Arnold A Portigal, Morris Schachnow and Jack Rabinovitch.

Urie, J (concurred in by MacKay, DJ):

Gibson, J:

1 I agree with the result found by the Tax Review Board and dismiss the appeal[s] with costs.

A. W. Prociuk, Q.C.:

The Chairman (orally; October 29, 1974):

1 This is an appeal by Arnold Prochnau against the reassessment of the Minister of National Revenue for the 1970 taxation year.

2 There is a similar appeal involving his brother Raymond Prochnau, and it is agreed by all parties that the decision in the Arnold Prochnau case will be binding in respect of the Raymond Prochnau case also.