The Chairman:—This is another appeal arising from the disallowance by the respondent of a claimed deduction from a company’s taxable income. The taxation year involved is 1966 and the place of hearing, Toronto.

A J Frost:—This is an appeal from income tax assessments for the appellant’s taxation years 1963, 1964, 1965 and 1966. Upon notices of objection, duly signed and filed, the Minister of National Revenue reconsidered the assessments and confirmed them on November 27,

A J Frost:—This is an appeal from a reassessment dated August 5, 1970 wherein the Minister of National Revenue adjusted the appellant’s income for the 1968 taxation year by including estimated United States earnings from September 15, 1968 to December 15, 1968 and

A J Frost:—This is an appeal from income tax assessments with respect to the appellant’s 1967 and 1968 taxation years. Upon notices of objection, duly signed and filed, the Minister of National Revenue reconsidered the assessments and confirmed them on the ground that

A J Frost:—This is an appeal from an income tax assessment in respect of the appellant’s 1968 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

J O Weldon:—This is an appeal against an assessment made under the Estate Tax Act, SC 1958, c 29 as amended, and was heard at Saskatoon, Saskatchewan, on October 12 and 13, 1971 under the Tax Appeal Board as it was then

W O Davis:—This appeal, which was heard before me at Toronto, Ontario, on September 27 and 28, 1971, at a sittings of the Tax Appeal Board as it was then constituted, is from a reassessment to income tax dated April 10, 1970, in respect of the appellant’s 1967 taxation year ended December 31. In assessing the appellant, the Minister of National Revenue included as part of the appellant’s income from its business a profit realized by it in its 1967 taxation year on the sale of an apartment building on June 13,1967.

A J Frost:—This is an income tax appeal in respect of the appellant’s 1969 taxation year. Upon notice of objection duly signed and filed, the Minister of National Revenue confirmed the assessment on April 29, 1971. The appeal was heard at St Catharines, Ontario, on November 29, 1971 by the Tax Appeal Board as it was then constituted.

The appellant worked in the United States and lived in Canada. By notice of assessment dated August 6, 1970 the appellant was assessed as follows:

A J Frost:—The appeal herein is hereby dismissed in respect of the taxation years 1966, 1967 and 1968 for the same reasons as are set out in the Reasons for Judgment issued concurrently herewith in Frederick Dennis Beauchamp v MNR.

Appeal dismissed.

KINGSTON DEVELOPMENT COMPANY LIMITED, Appellant.

and

MINISTER OF NATIONAL REVENUE, Respondent.

Tax Appeal Board (R S W Fordham, QC), November 8, 1971.

A J Frost:—This is an appeal from the appellant’s income tax assessments for the 1967 and 1968 taxation years. Upon notices of objection duly signed and filed, the Minister of National Revenue reconsidered the assessments and confirmed them on August 10, 1970. The appeal was heard at Toronto on October 26, 1971 by the Tax Appeal Board as it was then constituted.