The Chairman:—This is another of those troublesome appeals regarding the alleged association of certain private corporations, in this instance, during 1965, 1966 and 1967. The matter was heard at Montreal where the appellant, a Quebec company, carries on business as

J O Weldon:—This appeal with respect to the appellant’s 1967 taxation year was heard at Edmonton, Alberta, on October 19, 1971 under the Tax Appeal Board as it was then constituted.

J O Weldon:—This appeal with respect to the appellant’s 1967 taxation year was heard at Victoria, BC, on September 17 and 18, 1970 under the Tax Appeal Board as it was then constituted.

The Chairman:—Appellant is an Alberta corporation formed in 1949 and, until late in 1967, it was managed by one O L Spencer. It conducted an investment business and had a seat on the Calgary Stock Exchange. In 1967, Spencer and his family moved to Vancouver. All their shares of the appellant’s capital stock were then acquired by members of the family of Victor C Morrison, CA of Calgary, where this appeal was heard in April 1970 and judgment reserved. Assessments made in July 1969 and relating to the taxation years 1964, 1965 and 1967 require reviewing.

The Chief Justice (orally):—This is an appeal from a judgment of the Trial Division, dismissing an appeal from a judgment of the Tax Appeal Board, in so far as it dismissed appeals by the appellant from its assessments under Part I of the Income

The Associate Chief Justice:—This is an appeal from a decision of the Tax Appeal Board dismissing the taxpayer’s appeal from an assess- ment dated April 19, 1967 when a tax in the sum of $24,412.50 was levied in respect of the appellant’s 1966 taxation year

The Chief Justice (orally):—This is an appeal from a judgment of the Trial Division dismissing an appeal by the appellant from its assessments under Part I of the Income Tax Act for the 1966 and 1967 taxation years.

The Associate Chief Justice:—This is an appeal from an assessment made with respect to the appellant’s 1966 taxation year whereby a certain deduction made from her tax in that year pursuant to paragraph (b) of subsection (1) of section 33*

Kerr, J:—Two appeals herein by the said appellant against assessments of income tax were heard by the Exchequer Court of Canada, and by a judgment of that Court rendered on May 21, 1971 (reported [1971] CTC 325) the appeals were allowed and the assessments

Cattanach, J:—This is an appeal from a judgment of the Tax Appeal Board dismissing an appeal of the appellant herein from assessment to income tax for his 1961 taxation year. The merits of the appeal were not argued before the Tax Appeal Board. The