O’Connor, J.T.C.C.:— This appeal was heard in Toronto, Ontario on February 7, 1994 pursuant to the General Procedure of this Court.

Beaubier, J.T.C.C.:—This appeal was heard in Winnipeg, Manitoba on December 6 and 7, 1993, pursuant to the General Procedure of this Court.

Goetz, J.T.C.C.:— Well, in my recess I reviewed my notes, notes of evidence and the pertinent exhibits, and it's been decided that the appeal of Susan Alexandropoulos and that of Terry Scanlon be heard on common evidence, which they were. The

Christie, A.C.J.T.C.C.:—The year under appeal is 1987. There are two issues to be determined. First, the taxable capital gain realized by the appellant on the sale by it of 60 The Bridle Path, North York, Ontario ("the property”). Second, the liability

Bowman, J.T.C.C.:—This appeal is from an assessment for 1992. In fact the appellant endeavoured to raise the same issue for 1993 but since he had not yet been assessed for that year his purported appeal for 1993 was quashed.

Teskey, J.T.C.C.:—The appellants, Edith and George Kauntz, both elected to have these appeals heard on common evidence and pursuant to the informal procedure.

Kempo, J.T.C.C.:—These reasons were not formally read at the conclusion of the hearing as there was considerable exchange between the Court and Mr. Parks with respect to the equitable relief he was requesting and the jurisdictional limitations upon the Court

Christie, A.C.J.T.C.C.:—This appeal is governed by the informal procedure prescribed by section 18 and following sections of the Tax Court of Canada Act, R.S.C. 1985, c. T-2.