Rouleau, J.:—This is an appeal by way of trial de novo from the judgment of the Tax Court of Canada dated September 23, 1986 dismissing the plaintiff's challenge to the notice of assessment of the Minister of National Revenue

Strayer J.: —

Urie, J.A. (Heald and Hugessen, JJ.A. concurring): —The respondent in this appeal from a judgment of the Trial Division was successful both in that Court and in the Tax Review Board("the Board”) on his appeal from an

Dubé, J.:—These two income tax actions were heard together by consent and by order of the court. The issue in both cases is whether or not the sale of an apartment building, the Brookland Court, situated at 540 Helmcken Street, Vancouver, B.C.,

Strayer, ].: —

McNair, J.: —This Court orders by consent that the income tax returns of the plaintiff for the year 1980 be referred back to the defendant for reassessment on the basis that in computing the plaintiff's income for the taxation year 1980

Urie, J.: —For the reasons given in A-14-88, John E. Wiebe v. M.N.R., the section 28 application will be dismissed.

Application dismissed.

McDonald J.:—This is an application made to determine the entitlement to certain moneys of a debtor, International Warranty Company Ltd. ("I.W."). The contest is between Lloyds Bank ("the bank") the holder of an assignment of book debts made by I.W.

McNair J.:—These actions are appeals by the plaintiffs, pursuant to subsection 172(1) of the Income Tax Act, from a decision of the Tax Court of Canada dismissing their appeals from reassessments of their income for the 1979,

Reed, J.:—The applicant brings a motion pursuant to subsection 225.2(2) of the Income Tax Act, R.S.C. 1952, c. 148 as amended. This provision was added to the Income Tax Act in 1985 along with other provisions