Tremblay J.T.C.C.:-This appeal was heard pursuant to the informal procedure on March 28, 1994, in Québec City, Quebec.

Dussault J.T.C.C.:—This is an appeal from an assessment for the appellant’s 1987 taxation year. The case essentially concerns the method used by the Minister of National Revenue (the "Minister") to determine the tax under Part IV of the

Teskey J.T.C.C.:-This appeal was heard under the informal procedure.

Tremblay J.T.C.C.:—This appeal was heard in Montréal, Quebec on May 9, 1994.

Archambault J.T.C.C.:-These are appeals governed by the old rules of procedure disputing income tax assessments issued by the respondent for the 1985, 1986 and 1987 taxation years.

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.: