Brulé, TCJ:—This is an appeal to this Court by the taxpayer in which it becomes necessary to characterize a payment made on the termination of a management agreement as either capital or income.

Cardin, TCJ:—The Minister of National Revenue assessed Vittorio Coscarella, employing the “net worth” method of ascertaining income, and included in the computation of the appellant’s income for the 1976, 1977 and 1978 taxation years, amounts of $8,091.26, $16,917.04

Cardin, TCJ:—The issue is the deductibility of amounts of $15,317.51 and $26,828.29 claimed by Mario Monteiro as total farm losses incurred in the 1979 and 1980 taxation years respectively.

Kempo, TCJ:

Brulé, TCJ:—This appeal relates to the appellant’s 1977 to 1980 taxation years inclusive in which he is claiming to deduct full farming losses during this period.

Tremblay, TCJ:—This appeal was heard on May 16, 1984, in the city of Sudbury, Ontario.

Kempo, TCJ:

Cardin, TCJ:—The appeals of Kenneth W Scott and George H Silcox were heard on common evidence in the city of Toronto on October 5, 1984. The issue is the deductibility of rental losses claimed by each of the appellants in the 1978 and