The Chairman (orally: March 21, 1975):

1 This is an appeal by Immobiliare Canada Limited against a reassessment of the Minister of National Revenue for the 1966 taxation year. The point at issue is whether or not a transaction in which the appellant was involved required the appellant to withhold 15% of certain moneys paid to a non- resident corporation.

A J Frost:

1 This is an appeal from an income tax assessment dated June 6, 1974 in respect of the appellant's 1971 taxation year.

A W Prociuk:

The Chairman (orally: July 3, 1975):

The Assistant Chairman:

1 This is the appeal of ABC Diaper Service Inc from an income tax assessment in respect of the appellant's 1968, 1969 and 1970 taxation years.

2 By ministerial direction under subsection 138A(2) of the Income Tax Act the Minister in his assessment of the pertinent taxation years associated the appellant with Wee Folks Diaper Service Inc (hereinafter referred to as “Wee Folks”).

A W Prociuk:

Collier, J:

1 The plaintiff is claiming from the defendant an “allowable refund” of $474,008.59 and certain other relief. The claim is founded on subsection 133(6) of the Income Tax Act.[FN1: <p>RSC 1952, c 148 as amended by section 1 of SC 1970–71–72, c63. The amending provisions are commonly referred to as the new<em>Income Tax Act</em>or the new Act. I shall adopt that description.</p>]

Addy, J:

A J Frost:

1 This concerns three appeals, heard jointly at the City of Ottawa, Ontario, on March 17, 1975, from several income tax assessments with respect to appellant's 1970, 1971 and 1972 taxation years.

A W Prociuk (orally: October 29, 1975):