Noël, ACJ:—This is an appeal to this Court from the decision of the Tax Appeal Board on December 2, 1970, allowing an assessment for 1963 in which, on July 10, 1968, the Minister had added the sum of $18,514.91 to appellant’s income [sic] by refusing

Kerr, J:—This is an appeal against reassessments of income tax under the Income Tax Act on the appellant company for its 1966 and 1967 taxation years.

Walsh, J:—This is an appeal from income tax assessments dated January 30, 1964 and March 21, 1967 for appellant’s 1961 taxation year.

Cattanach, J:—These are appeals from the assessment by the Minister of the appellant to income tax for his 1967 and 1968 taxation years whereby the Minister disallowed the appellant’s claims to exemption from payment of tax in those respective taxation years pursuant

Walsh, J:—This is an appeal from a decision of the Tax Appeal Board dated December 16, 1969 confirming the assessment made on October 24, 1966, as slightly modified by reassessment dated February 29, 1968, of appellant’s income tax for the year 1965 whereby the

Gibson, J:— This is an appeal from an assessment for estate tax in respect to nine class “A” voting common shares in the capital stock of T Winram Co Ltd which shares comprised a part of the property passing on the death of Theodore James Winram, deceased, and which were assessed at an aggregate amount of $177,972.30. The executors in the return of information filed pursuant to the Estate Tax Act, declared the value of these shares to be $1,627.06 (which it is agreed should have read $1,780.61).

Gibson, J:—This is an appeal from a reassessment for income tax of the appellant for the taxation year 1966 in respect to an item in the amount of $1,201,079, which has been called “the aggregate net revenue decreases” from August 1, 1961 to November 19,

Collier, J:—This is an appeal from a decision of the Tax Appeal Board ([1969] Tax ABC 769). The Minister had reassessed the present respondent for its taxation years 1963, 1964 and 1965 and it successfully appealed to the Tax Appeal Board.

The evidence before this Court consisted of the evidence and proceedings before the Board with the addition of evidence from one witness called on behalf of the respondent.

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.