Beaubier J.T.C.C.: — This matter was heard at Toronto, Ontario, pursuant to the Informal Procedure on September 23, 1996. The Appellant was the only witness.

Isaac C.J.: — This is an appeal from a judgment of the Tax Court of Canada, dated 16 April, 1996, dismissing the appellant’s appeal from reassessments made under the Income Tax Act (the “Act”) for the taxation years

O’Connor J.T.C.C.: - These appeals were heard at Vancouver, British Columbia on September 19, 1996.

Tremblay J.T.C.C.: — This appeal was heard under the informal procedure at Québec City, Quebec, on October 4, 1995.

Christie A.C.J.T.C.: — The years under review are 1987 to 1991 inclusive. It is the position of the appellant that consequent upon the dissolution of a limited partnership named LRR Partnership Limited (“the partnership”) established under the

Dussault J.T.C.C.: - These appeals are from four different assessments, the notices of which, for the appellant’s 1989 taxation year, are number A186999 dated December 7, 1990, and number B200744 dated March 10, 1993, and for the appellant’s 1990

Rowe D.J.T.C.C.: — The appellant appeals from assessments of income tax for the 1991, 1992 and 1993 taxation years. In computing income for those taxation years the appellant deducted certain amounts as business losses which the Minister of National

Brulé J.T.C.C.: These appeals stem from a reassessment by the Minister of National Revenue wherein he disallowed a deduction of rental losses in the taxation years 1990, 1991 and 1992. The appellants are husband and wife and the appeals were heard

Bell J.T.C.C.: —

Christie A.C.J.T.C.: - This motion came on for hearing at Toronto on September 26, 1996. The litigation to which it relates is an appeal by Shell Canada Limited (“Shell”) under the Income Tax Act (“the Act”) in respect