REASONS FOR JUDGMENT

The case at bar was heard at Montreal, Quebec on september 21, 1976.

The Assistant Chairman:—The above-mentioned corporation (hereinafter sometimes called the “appellant”) has appealed to the Tax Review Board from an assessment for tax for each of the 1973 and 1974 taxation years. The issue between the parties is, as I

The Assistant Chairman:—The issue in this appeal is whether the expenditures the appellant made of $500 in 1971 and $18,751.70 in 1972 were within the ambit of paragraph 12(1 )(a) of the Income Tax Act before tax reform

The Chairman:—This is the appeal of Lebern Jewellery Co Ltd from income tax assessments in respect of the 1971, 1972 and 1973 taxation years.

A J Frost:—This is an appeal from a notice of reassessment dated February 21, 1975 with respect to the appellant’s 1973 taxation year and from a notification of the Minister wherein he confirmed the said assessment on the ground that

The Chairman:—This is an appeal of Gerald C Shangraw from an income tax assessment in respect of the 1973 taxation year.

The Chairman:—This is the appeal of Ronald Rooke from an income tax assessment in respect of the 1971 taxation year.

The Assistant Chairman:—This is an appeal in respect of an income tax assessment for the 1971 taxation year. This appeal was heard October 14 and 15, 1976 on common evidence with the appeal of Townsview Properties Limited from assessments for income tax in connection with its 1970 and 1971 taxation years.

For the reasons given in the Townsview Properties Limited appeal, the appeal is allowed and the assessment referred back to the respondent for reconsideration and reassessment in accordance with those reasons.

The Assistant Chairman:—Townsview Properties Limited (hereinafter sometimes called “Townsview”) has appealed to this Board from assessments for tax for its 1970 and 1971 taxation years. Another company, G Stanley Mann Investments Limited (hereinafter sometimes

The Chairman:—This is the appeal of John T Klue from an income tax assessment in respect of the 1974 taxation year.