Teskey, T.C.J.:—The appeals of Louis Ganci (Louis) and Guy Ganci (Guy) were heard together on common evidence. They appeal their 1984, 1985 and 1986 reassessments wherein the Minister classified the appellants as “Class 2" farmers as defined by Moldowan,

Tremblay, T.C.J.:—The hearing of this application for an extension of time was held on March 28, 1989, in Québec, Québec.

Christie, A.C.J.T.C.:—This is a test case. It is agreed that its disposition shall apply to 11 other appeals. [1]

Mogan, T.C.J.:—The appellant was a partner in a general partnership formed under the laws of British Columbia and under the firm name and style "Kanvan Group" (the "Partnership"). The purpose of the Partnership was to purchase certain land; to plan,

Sarchuk, T.C.J.:—Mark Harding appeals from reassessments made by the respondent with respect to his 1979 to 1985 taxation years inclusive. Initially a number of issues were before me; however the parties have consented to judgment being issued by this Court

Kempo, T.CJ.:—These appeals concern the appellant's 1979, 1981 and 1982 taxation years and were heard on common evidence.

Bonner, T.CJ.:—The appellants appeal from assessments of income tax for the 1981, 1982 and 1983 taxation years. At issue is the appropriate treatment of certain dividends. During the first two years the appellants held all the issued shares of Prince

Brulé, T.C.J.:—This is an appeal from a notice of assessment for the taxpayer's 1985 taxation year in which the Minister considered an affiliation fee paid to Best Western International Inc. to be a royalty and therefore subject to tax within the

Kempo, T.C.J.:—These appeals concern the appellant's 1985 and 1986 taxation years wherein the respondent had reassessed the appellant's income so as to add the amount of $10,795.37 to his 1985 income and the amount of $17,041.95 to his 1986 income on

Christie, A.C.J.T.C.:—This appeal relates to the appellant's 1983 taxation year. The issue is whether, in computing its income for that year, the appellant is entitled to deduct expenditures that it made of $175,026 as currently deductible expenses. In reassessing