Kerr, J.:—These two appeals were heard together on the same evidence.

CATTANACH, J.:—This is an appeal by the appellant, The Deltona Corporation, a corporation incorporated pursuant to the laws of the State of Delaware, one of the United States of America, and resident in the City of Miami, Florida also one of the United

GIBSON, J.:—This is an appeal from an assessment for estate tax made August 1, 1968 whereby tax in the sum of $61,444.95 was levied. This assessment added the sum of $93,828.21 to the estate tax payable for the value of certain inter vivos gifts made by the deceased Hubert Harry Harshman to what is called in these proceedings ‘ The Harshman Foundation’’, and for the value at the date of death of the gift to The Harshman Foundation under the will of the said Hubert Harry Harshman deceased.

JUDSON, J. (all concur) :—The appellant, Oakfield Developments (Toronto) Limited, is a private company provincially created by letters patent of amalgamation dated October 8, 1964. One of its predecessor corporations was Polestar Developments Limited. In respect of its two

MARTLAND, J. (all concur) :—This appeal is from the judgment of the Exchequer Court, which dismissed (save as to one agreed item) the appellant’s appeal from the assessment of its income tax, for the taxation year 1963, made by the respondent.

WALSH, J.:—This is an appeal from income tax assessments dated April 28, 1969 for the taxation years 1964 and 1965 of the appellant. On or about September 1, 1964, appellant, a Quebec corporation, established a pension plan for its employees entering into

DUMOULIN, J.:—By a notice of motion, argued in Court this 10th day of March, 1971, the respondent sought to obtain:

GIBSON, J.:—This is an appeal from the decision of the Tax Appeal Board, reported [1969] Tax A.B.C. 548, which disallowed the appellant’s appeal against a re-assessment for income for the taxation year 1965.

Judson, J. (all concur) :—The respondents are the executors of the last will and testament of Harris Cox, deceased. The sole issue on appeal is whether there is to be included in the property passing on the death of Harris Cox, the face value of a

WALSH, J.:—This is an appeal from re-assessments dated September 26, 1968 wherein a tax in the sum of $361,204.29 was levied in respect of income for the taxation year 1965 and a tax of nil was levied in respect of income for the taxation