Sobier, T.CJ.:—This appeal was heard at Toronto on August 28, 1990. At the outset, counsel for the appellant and the respondent agreed that the facts in this appeal are not in dispute.

Kempo, T.C.J.:—This appeal is from an assessment made under what is commonly known as the directors' liability provisions of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act").

Garon, T.C.J.:— These appeals involve a reassessment dated February 12, 1987 for the appellant's 1983 taxation year, a reassessment dated February 17, 1986 for the appellant's 1984 taxation year and a reassessment dated July 15, 1988 in respect of the

Teskey, T.C.J.:—The appellant appeals his reassessment dated April 25, 1989 issued for 1986, wherein his income was increased by $132,000 as a result of a stock option benefit pursuant to paragraph 7(1)(a) of the Income Tax Act,

Teskey, T.C.J.:—The appellant appeals his reassessment for the taxation year 1980 dated April 21, 1983.

Issues

The two issues in this appeal are whether:

King, D.J.T.C.:—The appellant is appealing from a reassessment for his 1986 taxation year.

Taylor, T.C.J.:— This is an appeal heard in Vancouver, British Columbia, on July 20, 1990, against an assessment in the amount of $15,060.44 being the amount for federal tax, provincial tax, Canada Pension Plan, Unemployment insurance, penalty and interest for

Bonner, T.C.J.:—The appellant appeals from assessments of income tax for its taxation years ending on April 30, 1984, 1985 and 1986. At issue is the amount of the resource allowance which, by virtue of paragraph 20(1)(v.1) of the Income

Mogan, T.C.J.:—The appeals of Herbert Liffman and David Wolinsky were heard together on common evidence. In 1980, Central Canadian Properties Ltd. ("CCP") loaned to each appellant the sum of $80,000. Identical promissory notes signed by the appellants provided for

Bonner, T.CJ.:—The appellant appeals from assessments of income tax for the 1984, 1985 and 1986 taxation years. Two aspects of the assessments are in dispute. Firstly, rental losses claimed by the appellant in respect of a condominium residence in Florida