Rip, J.T.C.C.:—Avis Immobilien G.M.B.H. ("Avis"), a non-resident of Canada, was assessed tax for 1986 pursuant to subsection 115(1) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act"). Avis has appealed the

Christie, A.C.J.T.C.C.:—The year under review is 1987. These appeals were heard together on common evidence. The appellants are husband and wife. The core issue is the appellants’ liability to income tax on amounts realized by them related to the disposition

Lamarre, J.T.C.C. (orally):—This is an appeal under the informal procedure from a reassessment issued by the Minister of National Revenue (hereinafter "the Minister"), in respect of the appellant's 1991 taxation year.

Sarchuk, J.T.C.C.:—This is an appeal from reassessments of tax for the 1987 and 1988 taxation years by virtue of which the Minister of National Revenue (the Minister) disallowed the deduction by the appellant of certain legal and accounting fees incurred

Mogan, J.T.C.C.:—The subject of this appeal with respect to the appellant's 1987 taxation year is an inducement payment by a landlord which requires an interpretation of paragraph 12(1)(x) of the Income Tax Act, R.S.C. 1952, c. 148

O’Connor, J.T.C.C.:—These appeals were heard in Ottawa, Ontario on October 19, 20 and 21, 1993 pursuant to the general procedure of this Court and relate to the appellant's 1986, 1987, 1988 and 1989 taxation years. In assessing, the Minister of National

Bowman, J.T.C.C.:—This appeal, from an assessment for the appellant’s 1986 taxation year, raises once again the question of the treatment under the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act"), prior to the coming

Brulé, J.T.C.C.:—The appellant has objected to the disallowance by the Minister of National Revenue ("Minister") of interest deductions paid in the 1985 and 1986 taxation years pursuant to paragraph 20(1 )(c) of the Income Tax Act, R.S.C.

McArthur, J.T.C.C.:—The appeals heard under the rules governing the informal procedure, are in respect to reassessments for taxation years 1989 and 1990. The appellant and the respondent were represented by competent counsel.

Lamarre, J.T.C.C.:—These are appeals under the informal procedure against the penalty levied on the appellant under subsection 163(2) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act") for the taxation