Martland, J (concurred in by Abbott, Ritchie and Laskin, JJ):—The question in issue in the present appeal is as to whether an amount of $1,000,000 paid to the respondent in October 1964 represented income received by it in the course of its trading operations.

Collier, J:—The appellant is a Canadian corporation which, in 1965, 1966 and 1967, carried on business both in Canada and the United States with a permanent establishment in both countries.

Cattanach, J:—This is an appeal from a decision of the Tax Appeal Board dated December 10, 1970, reported [1970] Tax ABC 1303, whereby the assessment of the appellant by the Minister with respect to its 1966 taxation year was confirmed.

Gibson, J:—These appeals were heard together on common evidence.

Collier, J:—This is an appeal from the Tax Appeal Board which dismissed the taxpayer’s appeal from a reassessment by the Minister in respect to the taxpayer’s income for the year 1966 (reported [1970] Tax ABC 1151).

Gibson, J:—In this action the Crown claims from the defendant consumption or sales tax, old age security tax, penalty interest, and other relief on the allegation, which is admitted, that during the period June 1, 1967 to September 30, 1968 the defendant sold or

Heald, J:—This is an appeal from an income tax reassessment dated October 18, 1969 for the taxation year 1966.

Collier, J:—This appeal, and another appeal in which Eco Exploration Company Limited (hereafter “Eco”) is the appellant, were heard in part commencing January 17, 1972. It was agreed the evidence in this particular appeal (Smerchanski) would be evidence, where applicable,

Heald, J:—This is an appeal from the decision of the Tax Appeal Board rendered on December 9, 1970 (reported [1970] Tax ABC 1265) dismissing the appeal by the appellant from reassessments for income tax with respect to its 1960, 1961, 1962 and 1963 taxation years.

The parties have agreed to a Special Case stated by consent pursuant to Rule 475.

Heald, J:—This is an appeal from the decision of the Tax Appeal Board rendered on December 9, 1970 (reported [1970] Tax ABC 1265) dismissing the appeal by the appellant from reassessments for income tax with respect to its 1960, 1961, 1962 and 1963 taxation years.

The parties have agreed to a Special Case stated by consent pursuant to Rule 475.