MacGuigan J.T.C.C.: - This is an appeal by Flexi-Coil Ltd. (“Flexi”) a farm machine manufacturer, from a decision by Archambault J.T.C.C., which confirmed income tax assessments of the Minister of National Revenue (the “Minister”) for the 1988 and 1989

Linden J.T.C.C.: — The issue in this appeal is whether the respondent taxpayer, Duha Printers (Western) Ltd., is permitted to deduct from its 1985 taxable income non-capital losses of $460,786. The taxpayer claims that the right to deduct the losses

Hugessen J.T.C.C.: — Mr. Justice Pratte and I are of the view that there was no manifest error in the Tax Court judge’s finding that the Appellant had undertaken to pay its subcontractor, Vidalin’s, employees and to withhold and remit

Hugessen J.T.C.C.: — The Appellant maintained horses which he raced. He argues that this resulted in his having two separate sources of business income: the maintenance of horses for racing and racing itself. Of these, only the former would fall

Foisy J. — The Attorney General of Canada (the “Attorney General”) is the appellant in this action. Roger M. Bourbonnais and Roger

Hugessen J.T.C.C.: — This is an appeal from a judgment of the Tax Court of Canada that dismissed the Appellant’s appeal to that Court.

Graser J.T.C.C.: - The parties were married on September 2, 1988. They separated October 8, 1994. There are two children aged six and four.

Both parties are employed full time. The applicant earns $28,000 - 35,000 gross per year and the respondent $36,000 per year.

Upon separation the respondent and children stayed in the marital home and the applicant paid the mortgage in lieu of child support until the sale of the home in December, 1994. Respondent provided applicant with a receipt for the payments for income tax purposes.

O’Connor J.T.C.C.: — These appeals were heard at London, Ontario, on October 1, 1996. Testimony was given by Daniel David Gascho, the president of the Appellant corporation and by Hélène Hébert, an appeals officer with Revenue Canada.

Sobier J.T.C.C.: — The Court is now prepared to give Reasons for Judgment in the appeal between Rosemarie Evertz and Her Majesty the Queen, 94-979(IT)G, and Dieter Evertz and Her Majesty the Queen, 94-980(IT)G. These appeals were heard on common