Tremblay, T.C.J.: —This appeal was heard on November 22 and 24, 1988 at the City of Montréal, Québec.

Kempo, T.C.J.:—These appeals are in respect of the appellant’s 1981 and 1983 taxation years and concern the replacement property provisions found within subsections 44(1) and 44(5) of the Income Tax Act (the "Act") which, in their

Kempo, T.C.J.:— These appeals were, on consent application, joined for hearing on common evidence. All three appeals dealt with assessments issued by the respondent pursuant to section 227.1 of the Income Tax Act (the "I.T.A.") commonly

Kempo, T.C.J.:—This appeal is from a notice of assessment Number 574429 dated November 12, 1986 for the amount of $32,387.05. It reads:

Taylor, T.C.J.:—These are appeals heard on common evidence in Calgary, Alberta on October 24, 1989, against income tax assessments for the year 1987 in which the Minister of National Revenue recalculated the reported income of the taxpayers with reference to

Christie, A.C.J.T.C.: —The notice of appeal and the reply thereto regarding this litigation relate to two issues. First is the disallowance by the respondent of a portion of the reserve claimed by the appellant under subparagraph 20(1)(n)(i) of the

Teskey, T.C.J.:—The appellant appeals his 1981, 1982 and 1983 reassessments.

Brule, T.C.J.:—There are three appellants before this Court. The first two are Mr. Kurt Pieckenhagen and his wife, Mrs. Julita Pieckenhagen. They are appealing reassessments for the 1977 taxation year. The third is Julita Investments Ltd. ("the Corporation") which

Christie, A.C.J.T.C.:— These appeals were heard together. The issue is the liability of the appellants as directors of a corporation in respect of tax deducted at source. Under paragraph 227(10)(a) of the Income Tax Act ("the Act")

Kempo, T.C.J.:—The present appeals are from reassessments for the appellant's 1981, 1982, 1983 and 1984 taxation years. Several distinct issues have been raised which will be dealt with separately.