Mahoney, J.A.:—This is an appeal from a judgment of Teitelbaum, J. rendered June 7, 1989, whereby an appeal by way of a trial de novo from decisions of the Tax Court of Canada in respect of reassessments to tax for the taxation

Muldoon, J.:—Three actions tried at once raise the identical contentious issue between the parties for the plaintiff's 1987 taxation year (T-2344-90), for the plaintiff's 1988 taxation year (T-2342-90) and for the plaintiff's 1989 taxation year (T-2343-90).

Teskey, T.C.C.J.:—The appellant appeals from a reassessment for taxation years 1988 and 1989.

Brulé, T.C.C.J.:—Two motions were presented to the Court, one by each party, as follows:

Sarchuk, T.C.C.J.:—This is an appeal by 454538 Ontario Ltd. (538) from an assessment of tax with respect to its 1981 taxation year. An appeal by 454539 Ontario Ltd. (539) from an assessment of tax for the same year is also before the Court.

Beaubier, T.C.C.J.:—This matter was heard in Ottawa on March 30, 1993. It is an appeal pursuant to the old procedure of this Court.

Beaubier, T.C.C.J.:—These matters were heard together on common evidence by consent of the parties, under the old procedure of this Court, on February 8, 1993 at Victoria, British Columbia.

Beaubier, T.C.C.J.:—This matter was heard at Toronto, Ontario, on March 8, 9, 10 and 12,1993 pursuant to the old procedure of this Court.

Beaubier, T.C.C.J.:—This matter was heard in Toronto, Ontario on March 11,1993. It is an appeal pursuant to the general procedure of this Court.

Mogan, T.C.C.J.:—The appeals of Angelo Testa and Libera Testa (husband and wife) were heard together on common evidence. The only issue in these appeals is the fair market value at December 31, 1971 (the "V-Day Value") of a certain parcel of land