Isaac C.J.:

This is an appeal from a judgment of the Tax Court, pronounced on 7 November 1996, allowing with costs, the appeal of the respondent, National Trust Company (“National Trust”) from an assessment made under section 224 of the Income Tax Act[1] for failure to comply with a requirement to pay.

Décary J.A.:

McKeown J.:

Christie A.C.J.T.C.:

1 These eight appeals were heard together. Each appellant seeks to deduct losses in computing his or her income. These losses pertain to the purchase of units of the capital in a partnership named Inter-Teck Oil Limited Partnership (“ITOLP”).

Smith A.O.:

Létourneau J.A.: