Joyal, J.: —For some time in the period relevant to this appeal, the workings of the Scientific Research Tax Credit System ("SRTC") under the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act") had been

Décary, J.A.:—The appellant is challenging a judgment of Cullen, J. rendered on May 11, 1989. A that time the trial judge, as requested by the respondent, vacated notices of reassessment by which the minister of National Revenue had, first, disallowed deductions

Rip, T.C.C.J.:—The appellant, Harvey Kalef ("Kalef"), in computing his income for each of 1983 and 1984, deducted amounts of interest paid on funds purportedly borrowed for the purpose of gaining or producing income from property: paragraph 20(1)(c) of the

Taylor, T.C.C.J.:—These are appeals heard in Toronto, Ontario on February 27,1991 against income assessments for the years 1983, 1984 and 1985 in which the Minister of National Revenue disallowed certain deductions claimed. The notice of appeal read in part:

Léger, C.C.I.:—Toutes les parties sont d'accord que les deux appels soient entendus en mème temps que le témoignage entendu est applicable aux deux litiges.

Mogan, T.C.C.J.:—For the years 1979, 1980, 1981 and 1982, the appellant did not file his income tax returns within the time prescribed in the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act"). Under subsection

Tes key, T.C.C.J.:—The appellant appeals from a reassessment of income tax, for the 1986 taxation year.

During the course of the trial, the appellant acknowledged that his appeal was concerning three issues, namely:

Teskey, T.C.C.J.:—The appellant appeals from a reassessment of income tax for the years 1984 and 1985 wherein the Minister of National Revenue (the "Minister") treated the gain on two sales of land as business income as opposed to a capital gain as

Tremblay, T.C.C.J.:—These appeals were heard on common evidence on July 3, 1991 at Québec, Québec.

Taylor, T.C.C.J.:—These are appeals heard in Toronto, Ontario on November 28 and 29, 1991 against income tax assessments struck in part for a liability applicable to both Michel Seguin and Barbara Seguin, under section 221.1 of the Income Tax