Tremblay J.T.C.C.: — This appeal was heard under the informal procedure at Québec, Quebec, on October 5, 1995.

McArthur J.T.C.C.: — This appeal was heard under the informal procedures of this Court.

O’Connor J.T.C.C. : — This appeal was heard at Ottawa, Ontario, on August 6, 1996 pursuant to the General Procedure of this Court.

Testimony on behalf of the Appellant (“Dew”) was given by Brian Smith, its vice-president engineering, James Pickard, a Program Manager and Engineer and Kevin Stewart, a representative of Public Works Canada who, in 1992, was a senior contract officer with the Department of Supply and Services.

Bell J.T.C.C. : —

Issue

The issue in respect of the Appellant’s 1992 taxation year is whether each of

Taylor J.T.C.C.: — These are appeals heard in Toronto, Ontario, on August 2, 1996 against assessments for the years 1991, 1992 and 1993, in which the Respondent had disallowed rental losses claimed against other income, under the Income

Sobier J.T.C.C. (orally): — The Appellant in this proceeding filed his Notice of Appeal with the Court apparently on or about January 29th, 1996 because there is a document called “Notice of Appeal, informal procedure” signed by Mr. Zhuang

Sobier J.T.C.C.: — This appeal was heard under the Informal Procedure of this Court.

Bowman J.T.C.C.: — These appeals from assessments for 1988 and 1989 involve a question of the deductibility of $3,688.52 and $27,915.46 in interest on a loan of $300,000.00. In brief the appellant contends that the borrowed money was used to

Bowman J.T.C.C.: — These appeals are from assessments for the 1989, 1990 and 1991 taxation years. They involve the deductibility of losses sustained by the appellant in respect of a single family dwelling in Tucson, Arizona. The principal basis of

Bowman J.T.C.C.: — These appeals were heard together on common evidence. They relate to assessments made under the Income Tax Act for the taxation years 1990, 1991 and 1992 of both the individual appellant and his