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

Sarchuk, T.CJ.: —By notice of assessment number 603910 dated November 7, 1986 the respondent assessed the appellant Donald Lindsay in the amount of $36,036.18 under subsection 160(2) of the Income Tax Act (the Act) as a

Lamarre Proulx, T.C.J.:—This appeal was heard at the same time as that of Mr. Jean Leduc, as the parties asked that the evidence be joined for these appeals.

Garon, T.C.J.:—These appeals concern income tax assessments dated July 6, 1987 and made by the respondent Minister of National Revenue for the taxation years 1980 to 1987 inclusive.