Lamarre Proulx, T.C.CJ.:— The appellant has appealed the income tax reassessments of the respondent, the Minister of National Revenue (the"Minister") for 1984, 1985 and 1986.

Brulé, T.C.C.J.:—These appeals involve the taxation years of 1978, 1979 and 1980 wherein the respondent reassessed the appellant by including amounts of $51,072.13 in 1978, $57,672.78 in 1979, and $17,625.49 in 1980. In addition penalties were added of $524.84

Beaubier, T.C.C.J.:—This matter was heard in Regina, Saskatchewan, on 14 October 1992. It is an appeal pursuant to the General Procedure of this Court.

Tremblay, T.C.C.J.:— This appeal was heard on November 1, 1990 and January 24, 1991, in Quebec City, Quebec.

Kempo, T.C.J.:—These appeals, on consent application, were joined for hearing on common evidence as the issues are interrelated. Counsel for the respondent advised the Court that the penalties levied against each appellant pursuant to subsection 163(2) of the

Beaubier, T.C.C.J.:—This matter was heard in Saskatoon, Saskatchewan, on October 5, 1992. It is an appeal pursuant to the General Procedure of this Court.

The appellant was the only witness.

Christie, A.C.J.T.C.:—The appellant was created by the amalgamation on December 31, 1988, of Leitch Transport Ltd. (“Leitch”), Leitch Transport Canada Ltd. and Upper Lakes Shipping Ltd. Upon the amalgamation the appellant became liable for the income tax indebtedness

Tremblay, T.C.C.J.:—These appeals were heard on common evidence on October 18, 1991 at Québec, Québec.

Sarchuk, T.C.CJ.:—The appeal of 598606 Ontario Ltd. [1] is from an assessment for its 1986 taxation year by which the Minister of National Revenue assessed the appellant in the amount of $99,380.51, being the Part VII tax owing

Pinard, J.:—This is an appeal by the plaintiff of reassessments by the Minister of National Revenue in respect of its 1984, 1985 and 1986 taxation years. At issue in this matter is whether the sums of $187,500 and $93,791 received by the