Bell J.T.C.C.: — These three appeals were heard on common evidence. Reference to the “Appellant” is a reference to each of the three Appellants, the procedures taken by the Minister of National Revenue (“Minister”) in respect of each of them

Bowman J.T.C.C.: — This appeal is from an assessment for the appellant’s 1987 taxation year. The issue is whether a loss sustained by the appellant of $206,221, together with related legal fees of $2,111, on a loan it made to a

Beaubier J.T.C.C.: — This appeal was heard at Saskatoon, Saskatchewan on June 26, 1996 pursuant to the Informal Procedure. The Appellant and her former husband, Joseph Larry Elder, both testified.

Archambault J.T.C.C.: — These are appeals by Mr. David Stein from income tax assessments by the Minister of national Revenue (Minister) for the 1986 and 1987 taxation years. The Minister disallowed the deduction of rental losses incurred in connection

Beaubier J.T.C.C.: — This appeal was heard at Kelowna, British Columbia, pursuant to the General Procedure on June 20, 1996. The Appellant was the only witness.

Sobier J.T.C.C.: — The Appellant appeals from the assessment by the Minister of National Revenue (the “Minister{}) of penalties under subsection 163(2) of the Income Tax Act (the “Act”) with respect to his 1989 and 1990

Beaubier J.T.C.C.: — These appeals were heard pursuant to the General Procedure at Kelowna, British Columbia, on June 20, 1996. The Appellant acted for himself and was the only witness.

Rip J.T.C.C.: — Longford Communications Limited (“Longford”) appeals (Informal Procedure) from an income tax assessment issued by the Minister of National Revenue (“Minister”) under section 160 of the Income Tax Act (“Act”). The Minister

Beaubier J.T.C.C.: — These matters were heard together on common evidence at Toronto, Ontario, on May 6 - 10 and May 13 - 17, 1996 inclusive, pursuant to the General Procedure.

McArthur J.T.C.C.: — This is an appeal from a Notice of Reassessment wherein the Minister of National Revenue (the “Minister”) reassessed the Appellant’s tax payable for the 1990 taxation year. The Appellant had claimed an allowable business investment