CATTANACH, J.:—This is an appeal under the Estate Tax Act from an assessment in respect of the estate of Charles 8. Christie, who died testate at the City of Saint John, in the Province of New Brunswick on August 10, 1964, by

Gibson, J. :—For about forty years before October 1, 1961, the decedent W. J. Fraleigh carried on a construction business in the City of Hamilton, Ontario, as an individual proprietorship. On October 1, 1961, he transferred certain of the assets of this

GIBSON, J.:—J. N. Sissons appeals from income tax re-assessments for the taxation years 1962 and 1963 whereby he was re-assessed for income tax by the inclusion as taxable income of an item of $57,000 in 1962 and an item of $30,000 in 1963, being

GIBSON, J.:—As at December 31, 1961, Consumers Distributing Company Limited had loaned the appellant $18,477.17. The appellant at that time owned beneficially all the issued shares of Consumers Distributing Company Limited. On April 15, 1962, the appellant caused to have

Gibson, J.:—For the purpose of deciding the issue in this appeal the parties agree that a $30,000 profit made by the appellant in a real estate transaction is income and not a capital gain.

BATSHAW, J.:—The Court, having heard the parties through their respective counsel on the merits of the present case, having examined the documents of record as well as the exhibits produced, having heard the evidence at the trial, and duly deliberated, now

JACKETT, P.:—This is an appeal from a Declaration of the Tariff Board that certain "‘transformers’’ are, within the meaning of paragraph (a) of Schedule V to the Excise Tax Act, "machinery and apparatus sold to or imported by

CATTANACH, J.:—These are appeals from the appellant’s assessments to income tax for its 1962 and 1963 taxation years which coincide with the calendar years.

DUMOULIN, J.:—This is an appeal from the Minister’s decision, dated July 27, 1967, affirming his previous assessment in the sum of $5,876.80 added, for taxation year 1964, to the appellant’s reported income. For reasons to follow the amount at issue, herein, is

GIBSON, J.:—The decision on this appeal under the Estate Tax Act is dependent on whether or not the appellant on April 9, 1964 was an “organization in Canada’’ within the meaning of those words in Section 7(1) (d) (i)*