Tremblay J.T.C.C.:-This appeal was heard on March 30, 1994, in Québec City, Quebec.

I. Point at issue

The point at issue is whether the appellant was correct

Kempo J.T.C.C.:—The informal procedure appeals of Shelly A. Collins and Barry Collins were, on consent application, joined for hearing on common evidence. They each pertain to their 1992 taxation year.

Sarchuk J.T.C.C.:-This is an appeal by Robert G. Caudle from an assessment of tax with respect to the 1991 and 1992 taxation years. He has elected the informal procedure pursuant to the provisions of section 18.1 of the Tax Court of

Bowman J.T.C.C.:-This is an appeal from the assessments for the 1989, 1990 and 1991 taxation years.

Originally, there were three points at issue, 1.e.:

Lamarre J.T.C.C.:-This is an appeal from an assessment issued against the appellant corporation for its 1989 taxation year, whereby the Minister of National Revenue, (hereinafter the Minister), disallowed the carryforward of a non-capital loss of $293,511 incurred by its

Archambault J.T.C.C.:—This is an appeal governed by the general procedure from an assessment for the 1987 taxation year. The appellant objected to the inclusion of the sum of $90,000 in its income by the Minister of National Revenue ("the Minister"). This

Bell J.T.C.C.:-The issue in this appeal, heard under the informal procedure rules, is whether the appellant’s share of profit from the sale of four properties in his 1986 taxation year, from the sale of one property in his 1987 taxation year and the

Rip J.T.C.C.:—The issue in these income tax appeals is whether certain scientific research and experimental development expenses were incurred by Dr. Valcav Hyrman or Cheakamus Holdings Ltd. ("Cheakamus") and Electro Medical Technology Corp. ("EMT"). The Minister of National

Rowe D.J.T.C.C.:—The appellant appeals from assessments of income tax with respect to its taxation years 1985-90, inclusive. By an agreement dated December 2, 1985, Elco Mining Limited (Elco) purchased from Fording Coal Limited (Fording) an interest in the Fording River