The Assistant Chairman (orally):—The appeal of Mary M Lindsey from an income tax assessment for the taxation year 1969 was heard in Toronto on January 22, 1973.

Roland St-Onge:—This appeal is from reassessments dated February 6, 1967, wherein taxes in the sums of $23,926.85 (plus interest of $20.28) and $55,992.77 (plus interest of $1,418.14) were levied in respect of income for the taxation years 1964 and 1965,

Roland St-Onge:—In 1968 appellant realized a profit of $86,317 on the sale of shares which it held in Fibracan Inc, hereinafter referred to as “Fibracan”. This profit was taxed as income; appellant however contends that it was a tax-exempt capital gain.

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