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.

Heald, J:—This is an appeal from a decision of the Tax Apeal Board rendered on December 7, 1970 (reported [1970] Tax ABC 1265) dismissing the appeal by the appellant from reassessments for income tax with respect to its 1960, 1961, 1962, 1963 and 1964

Walsh, J:—The facts of these two cases, which were heard together, are identical. Three companies were originally involved, the third being Terry Heights Realty Limited, which, however, paid its tax assessment for the year in question without protest. The fact that it

Cattanach, J:—This is an appeal by the Minister from a decision of the Tax Appeal Board rendered on October 29, 1970 (reported [1970] Tax ABC 1137) whereby an appeal against reassessments for tax, interest and penalties for the respondent’s 1965, 1966, 1967 and