Margeson, T.C.J.:—The appeal is against an assessment, notice of which was dated July 28, 1989 and numbered 0872, by which the appellant was assessed liability under subsection 227.1(1) of the Income Tax Act, R.S.C. 1952,

Tremblay, T.C.J. [Translation]:—This appeal was heard in the city of Montreal, Quebec, May 14, 1987.

Goetz, T.C.J. [Orally]:—The appellant is appealing against the assessment for his 1986 taxation year. The Minister's reply to the notice of appeal sets out the basic facts in paragraphs 5(a), (b), (c), (d), (e), (f), (g) and (h). They read as

Couture, C.J.T.C. [Translation]: —The taxpayer is appealing from an assessment for the 1981 and 1982 taxation years.

Tremblay T.C J. [Translation] : —This appeal was heard on November 25, 1988 in Montreal, Quebec, and the matter was taken under advisement on August 22, 1989 following receipt of the final arguments by counsel.

Tremblay T.C.J. [Translation]:—This appeal was heard on January 28, 1991 in the city of Sherbrooke, Quebec.

Goetz, T.CJ.: —In 1964 Stellio Bulietta incorporated Stan’s Transmission Centre Ltd., hereinafter referred to as ("Stan's") of Vancouver, British Columbia. Mr. Bulietta held 51 per cent of the corporation, his wife Anne held the remaining 49 per cent or

Sobier, T.C.J.: —The appellant appeals the reassessment by the respondent of his income tax for the 1985 taxation year whereby the respondent:

Dubienski, D.T.CJ.:— The appellant is the president of a conglomerate of companies under the corporate name of Jecco Group (hereinafter referred to as "Jecco"). This group carried on many businesses, including real estate developments and the assisting of financing

Taylor. T.CJ.:—This is an appeal heard in Edmonton, Alberta, on July 29, 1991, against an income tax assessment for the year 1988. The point at issue is the disallowance by the Minister of National Revenue ("respondent") of a claim by the taxpayer