Bowman J.T.C.C.: — This appeal is from an assessment for Goods and Service Tax. The problem in a nutshell is this. The appellant constructed five buildings forming a student learning facility adjacent to the campus of the University College of

Margeson J.T.C.C.: — It was agreed at the outset that evidence given in one would be considered in the other where applicable.

The Appellants appealed from an assesment for the 1991 taxation year, notice of which was dated January 18, 1994.

Bowman J.T.C.C.: — These appeals are from assessments made under section 227.1 of the Income Tax Act in the amount of $31,187.44 for unpaid deductions for provincial and federal income tax, Canada Pension Plan and Unemployment