Teskey, T.C.J.:—The appellant appeals its assessment dated March 7, 1989 wherein the Minister assessed a penalty pursuant to subsection 227(9) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act") for

Mogan, T.CJ.:— When the appellant applied to the Court for a hearing date, the respondent had not filed a reply to notice of appeal. The respondent therefore brought a motion under the Rules of Practice and Procedure asking leave to file a

Taylor, T.C.J.: —This is an appeal heard in Regina, Saskatchewan, on September 24, 1990, against an assessment dated October 20, 1989, under subsection 227(10) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c.

Taylor, T.C.J.:—This is an appeal heard in St. John's, Newfoundland, on August 23, 1990, against an assessment dated December 29, 1987, under subsection 227(10) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c.

Taylor, T.CJ.:—This is an appeal heard in Regina, Saskatchewan, on September 24, 1990, against an assessment dated August 11, 1988, under subsection 227(10) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63)

Beaubier, T.C.J.: —This case was heard in Regina, Saskatchewan, on August 16, 1990.

Garon, T.C.J.:—These five appeals, which were heard together on common evidence, involve two taxpayers who are husband and wife. There is no dispute about the facts. Appellant, Serafino Tiberio, testified briefly and he acted for himself and on behalf of

Christie, A.C.T.C.J.: —Lillian Lamash died at Victoria, British Columbia, on July 27, 1982. This appeal pertains to two basic issues arising under the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act") from

Sarchuk, T.C.J.:—At the conclusion of this appeal, counsel for the appellant sought costs and submitted that they should be awarded on a solicitor and client basis. He argued that the appellant had substantially succeeded in his appeal and that the