Giles A.S.P.:— The action in which this motion is brought may arise out of the income tax assessment of a numbered company. The numbered company has been dissolved by the Province of Ontario.

Dubé J:—This is an appeal by the plaintiff from a decision of the Tax Court of Canada which upheld notices of reassessment from the Minister of National Revenue ("the Minister”) in respect of the plaintiff's 1978, 1979, 1980 and 1981 taxation

Hugessen, J.A. (Robertson, J.A. and Gray, D.J. concurring):—The appellant appeals against two judgments (supported by a single set of reasons) rendered by McNair, J. in the Trial Division at [1990] 1 C.T.C. 196, 90 D.T.C. 6142.

Marceau J.A.:—This is an application by the Crown from a decision of the Tax Court in a case involving Part 1.2 of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act"). Part 1.2 was inserted

Wetston J. (orally):— I will state that this is a motion for an adjournment of what is now a dated tax case. The Associate Chief Justice by order dated September 7, 1994 denied a motion in writing to adjourn this matter.

Marceau J.A.:— We are all of the view that this application is without merit.

Letourneau J.A. (Robertson J.A. concurring):—

This appeal from a reassessment of the Minister of National Revenue dated September 25, 1989 and confirmed by notification of confirmation by the Minister dated August 31, 1990 came on for hearing at London, Ontario on May 4, 1994. At issue in this appeal

Dubé J:— This appeal by the plaintiff is from notices of reassessment issued by the Minister of National Revenue in respect of the plaintiff's 1985 and 1986 taxation years wherein he deemed the losses from the plaintiff's farming business to be