A W Prociuk:—The appellant, at all times material hereto, being an American citizen and resident, appeals from the Minister’s reassessment for the taxation year 1969 in the sum of $40,000 received from a Canadian source and on which a tax of

A W Prociuk (orally):—The appellant, formerly known as Radatzhe Brown Developments Ltd, appeals from an assessment for the taxation year 1967 wherein the Minister disallowed the use of the provisions of subsection 85E(4) in the determination of the

The Chairman (orally):—First of all, may I say this is not the first time that this particular problem has come before me, and it is never easy to explain my decision to the appellants.

A J Frost:—This is an appeal from the appellant’s income tax assessments for the 1968 and 1969 taxation years in which the only question to be decided is whether interest claimed by the appellant in respect of the indebtedness on a

Roland St-Onge:—This appeal is from an assessment dated September 22, 1970, wherein federal tax in the amount of $38,880.60 and provincial tax in the amount of $10,782.83 was levied in respect of income for the 1969 taxation year.

The Assistant Chairman:—The appeal of Mr Lucien Lapointe from assessments for the taxation years 1966, 1967, 1968 and 1969 was heard at Ottawa on November 24, 1972.

Walsh, J:—These two cases were heard together since the facts are identical save for certain differences in the amounts of the earnings of each of the defendants from their personal farming operations and in the amounts they received as remuneration from

Mahoney, J:—This is an appeal against the reassessment of the plaintiff’s 1967 income tax return whereby there was added to his income an amount of $6,037.56, being his share of the reduction for that year of a reserve established under section 85B

Thurlow, J (judgment delivered from the Bench, concurred in by Sheppard, DJ):—This is an appeal from a judgment of the Trial Division which dismissed the appellant’s appeal from a reassessment of income tax for the year 1965. By the reassessment in question the

Addy, J:—This is an application by the Minister of National Revenue by way of appeal from the Tax Appeal Board whereby the latter held that, for the taxation year 1964, Furnasman Ltd (hereinafter referred to as “Furnasman”) and Furnasman (Metal) Ltd