Urie, J:—This is an appeal from the decision of the Tax Review Board dated November 20, 1972, affirming an assessment relating to a profit realized by the plaintiff in his 1969 taxation year from the sale of a tugboat named

Lande, J:—The Court having examined the proceedings, studied the law and the written notes of the parties and having deliberated on the whole.

Sweet, DJ:—The Crown granted to the plaintiff, Jackson Brothers Logging Company Limited (herein referred to as Jackson) and Phillips and Lee Logging Limited (herein referred to as Phillips and Lee) timber sale harvesting licence A 00044 dated October 2, 1967

Cattanach, J:—The two appeals indicated in the above styles of cause came before the Court contemporaneously pursuant to an order dated June 23, 1970 given by the President of the Exchequer Court of Canada, now the Chief Justice of the Federal Court of Canada,

Sheppard, DJ:—The issue is the liability of the plaintiff to income tax on shares in his name under subparagraph 6(1)(a)(i) and subsection 16(1) of the Income Tax Act.

Fitzpatrick, J (orally):—Duncan J Morris is charged with five offences under paragraph 132(1 )(a) of the Income Tax Act and with one offence under paragraph 132(1)(d) of the same Act. The five offences under paragraph 132(1)(a) charge Mr Morris

Kerr, J:—This action was tried together with another action No 920-71 between Price (Nfld) Pulp & Paper Limited, as suppliant and Her Majesty the Queen, as respondent.* They were commenced by petitions of right in the Exchequer Court claiming refunds

Cattanach, J:—By order of Mr Justice Sheppard dated April 18, 1973, the four actions mentioned in the styles of cause above were placed on the trial list together to be heard at the same time on common evidence.

Bélanger, J.*—The Court, having heard the parties through their respective attorneys, on the merits of the present case, having examined the proceedings, the exhibits filed, the evidence adduced and on the whole deliberated:

Walsh, J:—This is an appeal from the decision of the Tax Appeal Board dated March 30, 1971, dismissing the taxpayer’s appeal with respect to its assessment for the 1966 taxation year.