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.

Garon, T.C.J. [Orally]: —In this case, the appellant appeals an income tax reassessment dated April 25, 1989, whereby the respondent disallowed the deduction in the amount of $7,500 claimed by the appellant in computing his income for the 1986 taxation

Bonner, T.C.J.:—This is an appeal from an assessment of income tax for the 1988 taxation year. At issue is the question whether salary received by the appellant during the year is exempt from taxation by virtue of Article 19 of the

Garon, T.C.J. [Orally]: —In the present case, the appellant appeals reassessments for the 1981 and 1982 taxation years. The issue in these appeals has to do with the deductibility of a payment in the sum of $443,000 made in 1981 to Ville