Kempo, T.C.J. [Orally] : — I am delivering these reasons for judgment orally, however I expressly reserve the right to edit and expand upon them subsequently if need be and I reserve the right to correct my arithmetic if it should happen to

Rip, T.CJ.: —Radiant Properties Inc. ("Radiant"), the appellant, appeals from an income tax assessment for its 1987 nation year in which the respondent included in income all of the profit from a disposition of real property. The appellant claims the

Mogan, T.C.J.:—In October 1983, the appellant purchased a house at 24 Nevada Avenue, Willowdale, Ontario, immediately north of Toronto. In order to finance that purchase, the appellant granted a second mortgage in the amount of $45,000 on the house at

Beaubier, T.C.J.:—This appeal was heard at the City of Toronto, Ontario, on May 2, 1991.

At the opening of trial, parties filed an agreed statement of facts which reads as follows:

Lamarre Proulx, T.C.J.: —This appeal concerns the year 1982.

Taylor, T.CJ.:— These are appeals heard on common evidence in Toronto, Ontario on February 26, 1991 against income tax assessments for the years 1984, 1985, 1986 and 1987 in the case of Patrick Daniel and the year 1987 for Jean Daniel. The

Margeson, T.CJ.: —In the case at bar, the appellant was an accountant by profession, who in the years 1981 to 1985 had claimed full farm losses from a thoroughbred horse operation known as "River Ridge Farms".

Taylor, T.CJ.:—This is an application for an extension of time within which to file notices of objection to notices of assessment dated August 29, 1989 for the taxation years 1983 and 1984. Mr. Michael's income tax returns for these years had been

Brulé, T.C.J. [Orally]: —In the matter of Michael Malowitz, applicant, versus the Minister of National Revenue, respondent.

Mogan, T.C.J.:—For the 1986 and 1987 taxation years, the appellant reported income from an active business carried on in Canada and claimed the small business deduction under subsection 125(1) of the Income Tax Act, R.S.C. 1952, c.