The Assistant Chairman:—This is an income tax appeal from assessments dated February 16, 1970 in respect of the appellant’s 1965 and 1966 taxation years which was heard at Windsor, Ontario on September 20, 1971 by Mr J O Weldon, QC, then a Member of the

A J Frost:—At the commencement of the hearing it was agreed by the parties that the appeals of Joseph Valevicius and Karl H Falk should be heard together on common evidence, as this was the most expeditious way to proceed. Two issues are involved, one

Maurice Boisvert:—This appeal is from assessments dated June 27, 1968 involving profits realized during 1966 and 1967.

A J Frost:—This is an income tax appeal in respect of the 1967 taxation year wherein, by reassessments of October 8, 1969 and August 31, 1970, appellant’s taxable income was readjusted as a result of an interest in the sale of land. This appeal was

Maurice Boisvert:—in this matter, three appeals were instituted by Marcel Giguére, René Giguere and Yvonne Giguere, all three being shareholders in a corporation known under the name of Giguère Automobile Ltée, which dates back to 1933 and which, since then, has

A J Frost:—These are income tax appeals in respect of appellant’s 1966 and 1967 taxation years. Upon Notices of Objection duly signed and filed, the Minister of National Revenue confirmed the assessments on the ground that the profit realized from the sale of

Maurice Boisvert:—This is an appeal from a reassessment dated January 6, 1969 in respect of income for the taxation year 1965.

The appeal was heard at Toronto, Ontario, in September 1971 by the Tax Appeal Board as it was then constituted.

A J Frost:—This is an income tax appeal in respect of the appellant’s 1967 taxation year. Upon notice of objection duly signed and filed, the Minister of National Revenue reconsidered the assessment and confirmed it on the ground that the taxpayer’s income had

The Chairman (orally from the Bench):—This is an appeal by the taxpayer, Fairgreen Investments Limited, against an assessment levied by the Minister for the taxation years 1967 and 1968. It also involves the appeals of two other taxpayers, Santana Developments Limited and

The Chairman (orally from the Bench):—Gentlemen, I am going to be as brief in my reasons as you have been in your arguments, because it is really a question of fact, as both of you have agreed.