The Assistant Chairman:—The appeal by La Cie d’Immeubles Courville Ltée from an assessment for the taxation years 1968 and 1969 was heard at Quebec City on December 8, 1972.

A J Frost:—This is an income tax appeal in respect of the 1965, 1966 and 1967 taxation years. The case was partially heard in Toronto, Ontario on September 18, 1972 and concluded in Hamilton, Ontario on October 19, 1972.

A J Frost:—It is ordered and adjudged that the judgment dated March 24, 1972 in respect of this appeal be hereby amended so as to allow the appeal in part and refer the matter back to the respondent for reassessment on the basis, as agreed to by the parties at the hearing, that the amounts of $375, $1,500 and $3,000 are deductible from appellant’s income for the taxation years 1965, 1966 and 1967, respectively. In all other respects the judgment issued on March 24, 1972 is affirmed.

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