HEALD, J.:—This is an appeal from income tax assessments of the appellant for its taxation years, 1964, 1965 and 1966. For the purposes of evidence and argument the appeals were united because the three cases are one and the same in fact and in law.

NoëL, A.C.J.:—The appeal is from a decision of the Tax Appeal Board, dated June 16, 1969 and reported [1969] Tax A.B.C. 691, dismissing the appeal of J. L. Guay Ltée, appellant, from an income tax assessment, dated September 20, 1968, by which a tax

VERCHERE, J.:—This is an application under Section 126A of the Income Tax Act to determine whether Paul Dennis Bowlen, Hambeldon Estates Ltd., Regent Tower Estates Ltd., Tico Estates S.A., The Paul Dennis Bowlen Trust, The Arvella Bowlen

HEALD, J.:—This is an appeal from an assessment against the estate of Elizabeth Ann Roberts wherein estate tax in the sum of $36,341.07 was assessed against the appellants as executors of the said estate.

PRATTE, J.:—The appellant appeals from income tax reassessments made upon him for the taxation years 1964, 1965 and 1966. In these re-assessments, dated April 27, 1970, the Minister of National Revenue added to the declared income of the appellant amounts of

CATTANACH, J.:—This is an appeal from the appellant’s income tax assessment for its 1961 taxation year.

The basic facts are not in dispute and are as follows.

Noël, A.C.J. (reasons for judgment continued) :—I have now received a letter from Messrs. Goodman and Carr, signed by Mr. Wolfe D. Goodman, Q.C., together with copies of a number of letters sent and received by the above firm. This material discloses that Mr. Goodman was consulted on this matter in July 1968 by Mr. Samuel Taylor, C.A., of the firm of Taylor, Leibow, Lukas and Ackerman, of Hamilton, and on July 18, 1968 gave an opinion on whether or not the assessment should be appealed.

CATTANACH, J.:—This is an appeal by the appellant from its assessment to income tax by the Minister for its 1965 taxation year.

Noël, J.:—The appeal is from a decision of the Tax Appeal Board, reported [1969] Tax A.B.C. 97, allowing in part an appeal by respondent against an assessment by the Minister under the Estate Tax Act, by which he levied a tax in

DUMOULIN, J.:—This appeal from the decision of the Tax Appeal Board, dated September 10, 1969, [1969] Tax A.B.C. 944, was heard and argued before the undersigned on May 31 of the current year, ultimate day of the erstwhile Exchequer Court’s legal existence