KERR, J.:—This is an appeal from income tax assessments in respect of the appellant’s taxation years 1964, 1965 and 1966* [1] whereby the respondent disallowed deductions claimed by the appellant in computing its income as having been paid by it

ABBOTT, J. (concurred in by Fauteux, Martland, Judson, Ritchie and Hall, JJ.) :—This appeal is from a judgment of the Exchequer Court which allowed an appeal under Section 58 of the Excise Tax Act, R.S.C. 1952, c. 100, as amended, by

DUMOULIN, J. :—This i is an appeal from a decision of the Tax Appeal Board, dated September 8, 1964, in respect of the assessment of Upstream Holdings Inc., of the city of Montreal, for the taxation year 1962.

JUDSON, J. (all concur) :—The problem in these two appeals is essentially the same as that in the Smythe appeals [[1969] C.T.C. 558]. Wilbour Lee Craddock and Stanley Curtis Atkinson were the principal shareholders in a private Saskatchewan corporation

N OËL, J.:—The respondent, by motion, moves that this Court quash the appellant’s notice of appeal, dated May 15, 1969, by which the latter appealed from an assessment for the year 1964, confirmed by a decision of the Tax Appeal Board, dated January

DUMOULIN, J.:—Clear-cut and uncomplicated, the facts giving rise to the moot question of law at issue are set out in the parties’ “Agreement as to Facts’’ filed of record on June 20 last.

GIBSON, J.:—This is an income tax appeal against re-assessments for the taxation years 1964 and 1965 of the appellant company Susan Hosiery Limited arising out of the disallowance of a deduction of $238,000 described in the re-assessments as “contributions made to

COUSINEAU, J.:—La Cour, sur le mérite de la présente cause, après avoir entendu les parties par leurs procureurs respectifs, ainsi que leur témoignage, avoir examiné la procédure, les pièces produites, entendu la preuve, et sur le tout délibéré :

KERR, J.:—This is an appeal from an assessment of income tax for the appellant’s 1965 taxation year. The question for determination is what part of the cost of certain property in Toronto, consisting of land and an office building, purchased by the appellant, can reasonably be regarded as being the ‘ consideration ’ ’ for ‘ disposition” of the building for the purposes of Section 20(6)

(g) of the Income Tax Act.

CATTANACH, J.:—These are appeals from a decision of the Tax Appeal Board, [1968] Tax A.B.C. 700, whereby the appeals of the eleven respondents named in the above styles of cause with respect to their respective assessments to income tax for their 1964