Tremblay, T.C.CJ.:—This appeal was heard on September 25, 1991, in the city of Montréal, Quebec.

Mogan, T.C.C.J.:—At all material times, the appellant was a substantial shareholder of Allcom Data Ltd. (referred to herein as "ADL") a Canadian- controlled private corporation as defined in the Income Tax Act, R.S.C. 1952,

Sarchuk, T.C.CJ.:—This is the appeal of Tri-Star Leasing (London) Inc. (TriStar) from assessments to tax with respect to its 1986, 1987 and 1988 taxation years.

Beaubier, T.C.C.J.:—These matters were heard together, on common evidence, by consent of all parties on February 12, 1992, on April 27, 28, 29, 1992, and May 1, 1992, in Winnipeg, Manitoba.

Mogan, T.C.C.J.:—The appellant is a farmer who resides near Goodsoil, Saskatchewan, a small community with a population of less than 300 located north-west of Saskatoon near the Alberta border. For his 1988 taxation year, the appellant claimed the" northern

Lamarre Proulx, T.C.C.J.:—The appellant appeals an income tax reassessment made by the respondent, the Minister of National Revenue (the"Minister") for the 1984 taxation year.

Sarchuk, T.C.C.J.:—The appeal of Melville Neuman with respect to his 1982 taxation year raises one issue, that being whether the dividend received by the appellants spouse paid on her Class" F” shares in Melru Ventures Inc. (Melru), was properly included

Kempo, T.C.C.J.:—The respondent on motion is seeking an order for an extension of time within which to file a reply to the notice of appeal of Alfred S. Carew (court file number 91-1503(IT) and to the notice of appeal of Arthur V. Carew

Rip, T.C.C.J.:—This is an appeal from an income tax assessment for the 1985 taxation year, in which the Minister of National Revenue, the respondent, added $7,500 to the income of Emile Mercier, the appellant, in accordance with subsection 14(1) of the

Rip, T.C.C.J.:—By notice dated April 29, 1987, bearing number 536592, the Minister of National Revenue, the respondent, assessed Robert B. Roll ("Roll"), the appellant, "under subsection 227.1(1) of the Income Tax Act, R.S.C. 1952,