Tremblay, T.C.J.:—This appeal was heard on August 26, 1987 and March 1, 1988 in Sherbrooke, Quebec. The Court reserved its decision on the appeal on November 7, 1988 when it received the last written pleadings.

Lamarre Proulx, T.C.J.:—This is an appeal from reassessments of income tax for the appellant's 1981 and 1982 taxation years.

Bonner, T.C.J. (orally):— Ideal Ship Repairs Ltd. ("Ideal") failed from May to August 1982 to remit amounts which it had withheld at source from employee wages as required by subsection 153(1) of the Income Tax Act. The appellant

Mogan, T.C.J.: —In 1982, the appellant became a limited partner in Janicek Associates, a limited partnership established for the purpose of conducting basic and applied scientific research in orbital mechanics and related fields of science and technology. In

Mogan, T.C.J.:—The appellants are husband and wife and their appeals were heard together on common evidence. In 1969, they came to Canada from Korea as a young couple and they became Canadian citizens in 1973. After working for a number of

Couture, C.J.T.C.:—This appeal is from an assessment issued by the respondent dated August 21, 1986 whereby the latter refused to allow the appellant to deduct a sum of $820,907 in computing its income for the 1983 taxation year.

Tremblay, T.C.J.:—This appeal was heard in Montréal, Quebec on April 19, 1988.

Christie, A.C.J.T.C.:—These appeals were heard together on common evidence. The appellants are husband and wife. Although Mr. Provias was present at the hearing, only Mrs. Provias testified.

Lamarre Proulx, T.C.J.:—This is an appeal from reassessments of income tax with respect to the appellant's 1982 and 1983 taxation years.

Lamarre Proulx, T.C.J.:—This is an appeal from the respondent's reassessments with respect to the appellant's 1981 and 1982 taxation years.