A W Prociuk (orally: June 12, 1975):

A W Prociuk (orally: January 27, 1975):

The Chairman (orally: May 13, 1975):

1 This is an appeal by Hugo Deuschle against reassessments of the Minister of National Revenue for the 1969, 1970 and 1971 taxation years.

2 The case is one of those that fall under the trading case heading and involves several transactions in the City of Penticton commencing in or about 1969.

Roland St-Onge (orally: March 3, 1975):

1 This appeal of Ross H Stanfield is from an assessment by the Minister of National Revenue dated June 8, 1973, wherein taxes with interest in the amounts of $143.04, $143.04 and $1,727.83 were levied in respect of the 1967, 1968 and 1969 taxation years.

The Assistant Chairman:

1 This is the appeal of Dr Emile S Shihadeh from an income tax assessment wherein a tax in the amount of $3,362.70 was levied against the appellant in the 1969 taxation year.

2 The issue in this appeal is whether the appellant qualifies for the exemption from taxation provided for in Article VIIIA of the Canada-US Tax Convention.

A J Frost:

1 This is an income tax appeal in respect of the appellant's 1969 and 1970 taxation years.

Thurlow, J (per curiam):

1 This appeal is from a judgment of the Trial Division which dismissed the appellant's claim for repayment of money paid by Dominion Engineering Works Limited as taxes in respect of the sale price of a paper making machine constructed by Dominion Engineering Works Limited for the appellant and installed in the appellant's premises by an engineering firm known as Rust Associates Ltd.

Décary, J:

1 The Court must determine whether the loss sustained by three shareholders in a company which was the owner of a building, as a consequence of expenses incurred by them in their capacity as tenants of the said building, is deductible for the purposes of paragraph 27(1)(e) of the Income Tax Act.

2 The Tax Review Board found that deduction of these expenses had unduly and artificially reduced the income of plaintiff.

Judge Flanigan (orally: November 22, 1974):

A J Frost: