Archambault T.C.J. (orally):

Hamlyn T.C.J.:

Bowie T . C.J.:

Bonner 7.C.J.:

This is an appeal from assessments under the Income Tax Act (“Act”) for the Appellant’s 1989, 1990 and 1991 taxation years.

Mogan T.C.J.:

Teskey T.C.J.:

The Appellant, in his Notice of Appeal wherein he appealed his 1995 reassessment of income tax, elected the Informal Procedure.

Lamarre Proulx T.C.J.:

This appeal concerns the interpretation of a clause in a lease entered into between two parties not dealing at arm’s length, the issue being whether the replacement of a roof is a “landlord’s repair”.

The Minister of National Revenue (the “Minister”) made the assumptions of fact set out in paragraph 14 of the Reply to the Notice of Appeal (the “Reply”) as follows:

a) At all material times, Mr. Joseph Caporicci was the only shareholder of the Appellant.

Lamarre Proulx T.C.J.:

The appellant is appealing a reassessment by the Minister of National Revenue (“the Minister”) for its 1989 taxation year.

The issues are:

Tremblay T.C.J.:

Bowman T. C.]. :