Roland St-Onge:—This appeal was heard at Vancouver, BC on October 26, 1971 by the Tax Appeal Board as it was then constituted.

In his statement of facts the appellant alleged the following:

Roland St-Onge:—This appeal was heard at Montreal, Province of Quebec, on March 18, 1971 by the Tax Appeal Board as it was then constituted. The question to be decided herein is whether a company known as Jodol Holdings Ltd carried on an active commercial

W O Davis:—Andrew Graham Tulloch has appealed from an assessment to income tax dated July 18, 1969 in respect of his 1964 taxation year, wherein the net proceeds from the sale of a vessel known as the “Sea Prince” have been added to his reported

Roland St-Onge:—This appeal was heard at Vancouver, BC on October 29, 1971 by the Tax Appeal Board as it was then constituted, and is from reassessments dated October 20, 1969 wherein tax in the amounts of $6,205.70, $4,019.39 and $10,194.14 was levied in

W O Davis:—In this matter, the appellant company has appealed from a notice of reassessment dated October 21, 1970, whereby the Minister of National Revenue informed the appellant that the tax payable by it in respect of its 1969 taxation year was nil.

A J Frost:—This is an appeal from four assessments, each one dated March 17, 1969, in respect of the appellant’s taxable income for the years 1963,1964, 1965 and 1966.

A J Frost:—This is an appeal from three income tax assessments each dated October 30, 1969 in respect of the appellant’s taxation years 1966, 1967 and 1968, wherein tax in the amounts of $80, $253 and $2,512.88 was levied. Upon Notices of Objection duly

J O Weldon:—This appeal with respect to the 1968 and 1969 taxation years having come on before me for hearing at Toronto on December 10, 1971 in the presence of George W Edmonds, Esq, QC, counsel for the appellant and R B Thomas, Esq, counsel for the Minister;

And upon hearing what was briefly stated by the appellant and alleged by counsel aforesaid, said counsel having also acted for the parties in the appeal of George Lenn Bowen v MNR, heard by the Board immediately prior to the hearing of the present appeal;

J O Weldon:—This appeal with respect to the appellant’s 1968 and 1969 taxation years was heard at Toronto on December 10, 1971 under the Tax Appeal Board as it was then constituted. The parties were represented by counsel as follows: George W Edmonds, Esq,

The Chairman:—The least that can be said of this income tax appeal is that it is a formidable one; the notice of appeal occupies 13 pages and these contain 39 paragraphs of allegations, plus a further 17 paragraphs of reasons for appealing, all of which