Roland St-Onge:—This appeal was heard at Edmonton, Alberta, on July 6, 1970, by the Tax Appeal Board as it was then constituted. The problem herein is whether Dr Besney is entitled, for the taxation years 1964 to 1967 inclusive, to deduct 100% of the

W O Davis:—These appellants being fellow members of the partnership association known as The R B White Clinic, of Penticton, BC, of which Dr William H White is also a participating member; and all three having appealed against assessments to income tax for the 1965 taxation year.

W O Davis:—The appellant is a medical practitioner residing at the city of Penticton, BC, where for a number of years he has practised medicine as a member of The R B White Clinic. This clinic is a partnership association consisting of the appellant and

The Chairman:—The taxpayer, a resident of Willowdale, Ontario, is employed as a securities salesman by Thomson & McKinnon Inc, Brokers. In addition he purports to perform bookkeeping and accounting services at his residence. As regards both occupations he appeals

A J Frost:—This is an appeal from reassessments dated February 13, 1970, concerning the appellant’s 1966 and 1967 tax years with respect to which a dispute arose regarding the taxation of annuity payments received by the appellant from Canada Life Assurance Company.

W O Davis:—This appeal was heard at Penticton, BC during the first week of May 1970 before the Tax Appeal Board, in conjunction with the appeals of William H White and four other members of The R B White Clinic in that city; and for the reasons given, and to the extent indicated, in my reasons for judgment in the appeal of William H White v MNR issued this day (p.

W O Davis:—This appeal was heard at Penticton, BC, in the first week of May 1970 in conjunction with the appeals of five fellow members of The R B White Clinic, including Dr William H White, and, for the reasons given and to the extent indicated

The Chairman:—This taxpayer’s appeal was heard at the same time as that of Murray Kadis, it then being agreed by counsel concerned that the evidence adduced should apply to both appellants.

The Chairman:—This income tax appeal was disposed of at the finish of its hearing, at Toronto, and it only remains necessary to record the reasons for the decision then reached by me. A reassessment relating to 1966 was involved whereby the sum of $19,067.82

Roland St-Onge:—The issue to be decided in this appeal is whether or not the respondent was justified in the assessing of penalties against the appellant in the amounts of $281.46, $893.86 and $1,098.80 with respect to the taxation years 1965, 1966 and 1967