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

Mogan, T.C.J.: — The issue in this appeal is whether an amount of $36,950 received by the appellant in 1981 in connection with the sale of a business in 1978 is a “retiring allowance” within the meaning of subparagraph 56(1)(a)(ii) of the

Tremblay, T.C.J.:—This appeal was heard on common evidence with the appeal of Monique Beauregard (87-646 (IT)) in Montréal, Quebec on October 14, 1988.

Lamarre Proulx, T.C.J.:—The appellant is appealing from an assessment by the respondent, Minister of National Revenue, made pursuant to section 227.1 of the Income Tax Act, ("the Act”).

Tremblay, T.C.J.: —This appeal was heard on November 23, 1988 at the City of Montreal, Québec.

Bonner, T.CJ.:—This is an application by way of interlocutory motion for judgment vacating the assessments under appeal on the ground that the delay in hearing the appeals is so great and so unreasonable that (a) the appellant's rights under paragraph

Couture, C.J.T.C.:—The above appeals were heard on common evidence at the request of counsel. While some of the facts may be slightly different in each of these appeals the differences are not substantial and have no bearing on their determination.

Christie, A.CJ.T.C.:— These appeals were heard together on common evidence. They relate to the 1984 taxation year of each appellant. In respect of that year the respondent reassessed Bhagat Ram Pallan by including in his income $142,491.49 being an alleged