Taylor, T.C.C.J.:—These are appeals heard in Toronto, Ontario, on April 1, 1992, against income tax assessments for the years 1985 and 1986 in which the Minister of National Revenue included in the calculation of the Gross Investment Revenue (G.I.R.) of

Mogan, J.T.C.C.:—This is an appeal in respect of the appellant's 1988 taxation year. The respondent admitted all of the facts alleged in the notice of appeal and no evidence (oral or documentary) was entered at the hearing. The appeal was argued on

Tremblay, T.C.C.J.:—This appeal was heard on November 26 and 27,1991 at Montreal, Quebec. The transcript was received by the Court on January 27, 1992.

Garon, T.C.C.J.:—By his motion, the applicant is seeking an order:

1. (a) for default judgment pursuant to paragraph 63(2)(c) of the Tax Court Rules; or, failing (a),

Garon, T.C.C.J.:—In this case, the appellant appeals a reassessment of income tax dated October 3, 1988 pursuant to which the amount of $103,640 was added to the appellant's income for its 1985 taxation year.

Christie, A.C.J.T.C.C.:—These appeals pertain to reassessments by the respondent regarding the appellant's 1984 and 1985 taxation years. In reassessing he added $76,723 to income for 1984 and $85,056 for 1985.

Garon, T.C.C.J.:—This is an appeal from a reassessment dated May 12, 1988, in respect of the appellants 1987 taxation year. By this reassessment the Minister of National Revenue reduced the investment tax credit from $31,609 to $22,204. This reduction in

Mogan, T.C.C.}. (orally):—There are a number of issues in this appeal and, while the facts are fresh in my mind, I propose to give my decision this afternoon on certain issues and reserve with respect to certain others.

Allan, T.C.C.J.:—In this case the appellant has claimed expenses personally incurred by him during the taxation year which have been disallowed by the Minister on the basis that they were capital in nature and not his expenses, but those of a company which took

Garon, T.C.C.J. (orally):—These cases are appeals from reassessments dated June 16, 1989 relating to the 1985, 1986 and 1987 taxation years. By these assessments, the Minister of National Revenue decided that as a result of a transaction dated June 26, 1985, which will