Lamarre Proulx, T.C.J. [Translation]:—These appeals were heard on common evidence. They concern the application of section 227.1 of the Income Tax Act ("the Act"), dealing with the liability of the directors of a corporation who fail

Rip, T.CJ.:—Norton Penturn, the appellant, filed appeals to this Court from income tax assessments for 1977 to 1982 inclusive. [1] The appellant describes himself as a financial intermediary or merchant banker who carries on the business

Mogan, T.C.J.:—Each year, the appellant computed his income and filed an income tax return. For the taxation years 1978, 1979, 1980 and 1981, the respondent issued to the appellant notices of reassessment based on a "statement of net worth" prepared by

Tremblay, T.C.J. [Translation]:—This appeal was heard on April 19, 1988 and on August 30 and 31 and September 2, 1988 in the city of Montreal, Quebec.

Taylor T.C.J.:—These are appeals heard in Saskatoon, Saskatchewan, on November 24,1989 with respect to income tax assessments for the years 1982, 1983 and 1984. The statement of facts filed by the appellant indicated:

Brule, T.C.J.:—The appellants appeal from income tax reassessments for the taxation years 1983 and 1984. At the opening of the hearing it was agreed that these appeals be heard on common evidence.

Bonner, T.C.J.:—This is an appeal from an assessment of income tax for the 1985 taxation year. At issue is the question whether certain legal fees are deductible in the computation of the income of the appellant estate. In disallowing the deduction

Mogan, T.CJ.:—The appellant filed his 1983 income tax return on or about March 17, 1987. The Department of National Revenue, Taxation Division, issued to the appellant a notice of assessment dated July 8, 1988 with respect to his 1983 taxation year

Mogan, T.C.J.:—The appeals of Albert Wong and Darlene Wong (husband and wife) were heard together on common evidence. Each appellant has instituted one appeal with respect to the taxation years 1982 and 1983 and a second appeal with respect to the

Christie, A.C.J.T.C.:—As I accept the applicant's evidence about nonreceipt of the notice of reassessment in respect of her 1983 taxation year, I believe I should make the same kind of order as made by Judge Brulé on May 25, 1988, in respect