Cattanach, J:—These are appeals from the appellant’s assessments to income tax by the Minister for its 1964, 1965 and 1966 taxation years. The assessments were made following directions by the Minister dated August 16, 1968 pursuant to the provisions of subsection 138A(2) of the Income Tax Act that the following companies are deemed to be associated with each other in their 1965 and 1966 taxation years:

(1) Loewen Holdings Ltd

(2) C T Loewen & Sons (1957) Ltd

(3) Build-A-Home Co, Ltd

Collier, J:—This appeal, which was argued on an Agreed Statement of Facts, is from an assessment by the respondent whereby the appellant company’s income tax for the year 1965 was increased by the sum of $60,125.99.

Martland, J (all concur):—By his will, made on August 21, 1962, the late Percival Archibald Woodward, hereinafter referred to as “the testator”, directed his executors to grant, transfer, assign, deliver and set over to Mr and Mrs P A Woodward’s Foundation, hereinafter

Martland, J (all concur):—This appeal is from a judgment of the Exchequer Court, which allowed the appeals of James A Cameron, the respondent in the present appeal, from assessments to income tax for his 1965 and 1966 taxation years.

Sheppard, DJ:—The facts and proceedings are fully set out in the Reasons for Judgment of the learned trial judge and need not be repeated here.

Cattanach, J:—This is an appeal by the Minister from a decision of the Tax Appeal Board dated February 23, 1971 whereby appeals by the respondents herein from their assessments to income tax for their 1963 and 1964 taxation years were allowed.

Cattanach, J:—This is an appeal from a decision of the Tax Appeal Board dated December 1969 in respect of the assessments of the appellant by the Minister to income tax for the appellant’s 1961, 1963 and 1964 taxation years.

Cameron, DJ (judgment of the Court delivered from the Bench):— This is an appeal from a judgment of the Trial Division delivered on June 11, 1971, allowing an appeal from the respondent’s assessments under Part I of the Income Tax Act

The Chief Justice (concurred in by Sheppard, DJ, judgment delivered from the Bench):—This is an appeal from a decision of the Trial Division dated June 13, 1972 dismissing an application for an order dismissing this appeal, which was brought by way of a statement

Abbott, J (all concur):—The respondent was incorporated in 1953 under The Corporations Act of Ontario, but its principal business was that of exploring for minerals in Ireland. At all material times, the management and control of the respondent (and