Hugessen, J.A.:—This is an appeal from a judgment of Cullen, J. ([1988] 2 C.T.C. 213; 88 D.T.C. 6410). The only issue is with respect to the scope of an election made by the taxpayer under section 85 of the Income Tax Act,

Cullen, J.:— This is an action appealing a decision of the Tax Court of Canada concerning the plaintiff's 1983 taxation year.

Urie, J.A.:—There are three respondents in the six appeals at present before the Court. Each respondent was a plaintiff in appeals which came before the Trial Division in respect of assessments made against them by the Minister of National Revenue ("the

Strayer, ].: —

Desjardins, J.A.:—The sole question for determination in this appeal is whether a payment made by the respondent, in order to extinguish a stock option plan held in favour of certain of its officers and key employees, constitutes a deductible expense or

Marceau, J.A.:— We are of the view that the order of the Associate Chief Justice, made on July 24,1990 on an application by the appellant for an order authorizing the Minister of National Revenue to take certain collection action against the

MacKay, J.: —This is an appeal by the plaintiff Her Majesty The Queen from a decision of the Tax Court of Canada, dated February 22, 1988, which allowed the defendant taxpayer's appeal from a notice of reassessment of income tax made by

Joyal, J.: —This is an appeal by the plaintiff, a company incorporated under the laws of British Columbia, from a reassessment for income tax purposes for the taxation year 1980. The plaintiff alleges that not only is the reassessment wrong on

Reed, J.:—The Minister of National Revenue seeks an order pursuant to subsection 231.3(6) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act") allowing him to retain documents seized from certain of

Teitelbaum, J.:—Counsel for the plaintiffs and defendant have made a request thai both cases be heard together on common evidence. I granted this request and the herein judgment shall apply to both files.