Beaubier, T.C.C.J.:—These matters were argued together before the Court in Vancouver, British Columbia on January 21, 1992.

Tremblay, T.C.C.J.:—This appeal was heard on June 6, 1990 at the City of Halifax, Nova Scotia.

Dussault, T.C.C.J.:—

Hamlyn. T.C.C.J.:—Donald Funk the appellant, appeals from a reassessment of income tax for the 1981 taxation year. The Minister of National Revenue reassessed Mr. Funk, pursuant to paragraph 18(1)(b) of the Income Tax Act, R.S.C. 1952,

Garon, T.C.C.J.:—This is an appeal from an income tax assessment made on May 23, 1988 for the 1986 taxation year. According to the amended reply to the notice of appeal, the Minister of National Revenue disallowed a deduction in the amount of

Sarchuk, T.C.C.J.:—This is an appeal by Simone Rita Balz, Executrix of the Estate of Frank Bernhard Balz from a reassessment of income tax with respect to the 1987 taxation year.

Allan, D.T.C.C.J.:—The taxpayer has appealed from the respondent's assessment of his 1989 return of income.

The parties to this appeal filed an agreed statement of facts, as follows:

Kempo, T.C.C.J.:—The appeals of United Color and Chemicals Ltd. (the "company") and of Otto Vass were, on consent application, heard on common evidence. The years under appeal and the essential issues raised were common to both appellants.

Christie, A.C.J.T.C.C.:—On December 22, 1986, the appellant transferred real estate located on 8th Street in the City of Saskatoon that is legally described as NW /419-36-4 W 3rd ("the Kosten property") to Boychuk Develop- ments Ltd. It is the contention