Lamarre Proulx, T.C.J.:—These appeals were heard on common evidence and concerned the liability of directors under subsection 227.1(1) of the Income Tax Act (the "Act"). The facts on which the respondent, the Minister of National Revenue,

Taylor, T.CJ.:—These are appeals heard on common evidence in Vancouver, British Columbia, on July 17, 1990, against income tax assessments as follows:

Aditex Development Ltd. ("Aditex")

Lamarre Proulx, T.C.J. [Translation]:—This is an appeal against a reassessment by the respondent, the Minister of National Revenue, with respect to the 1985 taxation year.

Kempo, T.CJ.:—The appeals of Joseph Fowler concern his 1985 and 1986 earnings in Canada. He resides in the United States of America and his Canadian earnings arose out of his selling activities at the Pacific National Exhibition ("PNE") in Vancouver.

Garon, T.C.J.:—This is an appeal from an assessment no. 581645 dated August 28, 1986 made by the respondent in respect of the appellant's liability as a director under subsection 227.1(1) of the Income Tax Act. The assessment is

Garon, T.C.J. [Translation]:—This is an appeal from an income tax assessment established by the respondent with respect to the income of Jean Thomas Lavigne (“Mr. Lavigne”) for the portion of the year preceding his death on July 3, 1983. Mr. Lavigne

Brulé, T.C.J.:—This appeal involves the taxation years 1985 and 1987 of the appellant in which he was reassessed. In 1985 issue involves the disallowance of a terminal loss while in 1987 a request for treatment of an averaging amount was denied.

Kempo, T.C.J.:—This appeal concerns the appellant's 1986 taxation year wherein the respondent had assessed to income the amount of $4,757.59 on the premise that it was dividend income pursuant to subsection 52(3) of the Income Tax Act

Christie, A.C.J.T.C.:—The dispute is about the deductibility of interest in computing the appellant's income for 1985, 1986 and 1987. The amounts involved are $19,400, $22,271 and $20,500 respectively.

Lamarre Proulx, T.C.J.:—This is an appeal against reassessments by the respondent, the Minister of National Revenue, for the year 1984 and 1985.

The points at issue are: