Archambault J.T.C.C.:—The respondent filed with the Court an application pursuant to section 58 of the Tax Court of Canada Rules (General Procedure) (the ’’Rules”) for the determination of a question of law. Solicitor for the appellant opposed this application and

Taylor J.T.C.C.:-These are appeals heard in St. Johns, Newfoundland, on April 13, 1994, under the informal procedure of the Tax Court of Canada, against reassessments for the years 1989, 1990, 1991 and 1992, in which the respondent disallowed claims for non refundable

Kempo J.T.C.C.:-This appeal concerns an inclusion into the appellant’s income by the respondent, acting through the Minister of National Revenue (the ’’Minister"), of a purported taxable benefit pursuant to subsection 245(2) of the Income Tax Act, R.S.C.

Sobier J.T.C.C.:-The appellant elected to have his appeal heard pursuant to the informal procedure.

Mogan J.T.C.C.:—Under the terms of a 49-page agreement dated May 15, 1987, the appellant borrowed $35,000,000 from Giant Resources Ltd., a company incorporated in the state of Queensland, Australia. Interest on the loan was payable monthly in arrears on the first

Bowman J.T.C.C.:—Continental Bank of Canada (”CB”) appeals from assessments for its 1986 and 1987 taxation years. Its wholly owned subsidiary, Continental Bank Leasing Corporation (”CBL”) appeals from an assessment for its 1987 taxation year. The appeals were heard together.

McArthur J.T.C.C.:-This appeal was heard in Calgary, Alberta, July 12, 13 and 14, 1994 pursuant to the general procedure of this Court.

Teskey, J.T.C.C.:—The appellant appeals her assessments of income tax for the years 1989, 1990 and 1991 and has elected to have her appeals heard pursuant to the informal procedure.

Bonner J.T.C.C.:-This is an appeal from an assessment of income tax for the appellant’s 1984 taxation year. During that year, the appellant entered into an Agreement in writing (the ’’Farmout agreement") with Esso Resources Canada Ltd. ("Esso"). Under the

McArthur J.T.C.C.:-This appeal was heard in Toronto, Ontario, on August 12, 1994, under the informal procedure of this Court concerning the appellant’s 1991 taxation year.