Rip J.T.C.C.: — Thiele Drywall Inc., the appellant, has appealed (Informal Procedure) assessments of income tax for its 1990 and 1991 taxation years in which the Minister of National Revenue (“Minister”) disallowed its claim for the deduction of legal

Bowie J.T.C.C.: — Section 118.3 of the Income Tax Act provides a deduction from income tax payable for individuals who suffer from a severe and prolonged mental or physical impairment. The amount of the deduction is not

Hamlyn J.T.C.C.: - These appeals for the 1989, 1990 and 1991 taxation years were heard under the informal procedure.

Bowman J.T.C.C.: — These are appeals from assessments for the 1989 and 1991 taxation years.

Archambault J.T.C.C.: — Gestion Bertal Inc. (Bertal) is contesting an income tax assessment by the Minister of National Revenue (Minister) for the 1988 taxation year whereby the Minister taxed a capital gain of $284,812.

Beaubier J.T.C.C.: — This matter was heard at London, Ontario on May 24, 1996 pursuant to the Informal Procedure. The Appellant was the only witness.

McArthur J.T.C.C.: — This appeal was heard in Toronto, Ontario, on April 26, 1996, under the Informal Procedures of this Court.

O’Connor J.T.C.C.: — This appeal was heard in Toronto, Ontario on February 29, 1996 pursuant to the Informal Procedure of this Court.

The Appellant represented herself, gave testimony and filed several exhibits.

Archambault J.T.C.C.: — These are appeals by Synchrosat Limited (Synchrosat) from income tax assessments by the Minister of National Revenue (Minister) for the 1991 and 1992 taxation years.

Sobier J.T.C.C.: — The Appellant appeals from the assessment of the Minister of National Revenue (the “Minister”) for its taxation year ended June 30, 1991, whereby the Minister disallowed a deduction in respect of holdbacks and billings invoiced to