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.

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,