Chevalier D.J.: — Between 1977 and 1979 David, Cindy and Brian Ludmer (the “Ludmers”) and Ludco Enterprises Ltd. (“Ludco”) bought shares in companies having their headquarters outside Canada. They obtained loans to pay for these shares. In their tax

Stone J.A.:-In our opinion this application for judicial review must fail. As a second application, in court file A-337-94, raises the same issue, these reasons will be filed in that matter and shall become the reasons for judgment of the Court

Hugessen J.A.:—We are all of the view that the present case is indistinguishable from this Court’s decision in Canada v. Veritas Seismic (1987) Ltd., [1994] 1 C.T.C. 241, 94 D.T.C. 6123. In that case the taxpayer used

Strayer J.A.:-On May 31, 1993 the plaintiffs commenced this action. On application of the first-named respondents (hereafter referred to as "the Crown") the associate senior prothonotary on July 19, 1993 struck out the statement of claim as disclosing no cause of

Stone, J.A.:-This is an appeal from a judgment of the Tax Court of Canada which dismissed appeals against assessments made under paragraphs 60(b) and (c) of the Income Tax Act R.S.C. 1952, c. 148, as amended for the 1984 and

Teskey J.T.C.C.: - The Appellant in his Notice of Appeal wherein he appealed his assessment of income tax for the year 1988 elected to have his appeal heard pursuant to the Informal Procedure.

Hamlyn J.T.C.C.: — These appeals were heard under the Informal Procedure and relate to the Appellant’s 1990 and 1991 taxation years.

Sarchuk J.T.C.C.: — This is the matter of Susan Zlot. Ms Zlot has appealed from an assessment of tax for the 1990, 1991 and 1992 taxation years. Pursuant to the provisions of section 18.1 of the Tax Court of Canada

Archambault J.T.C.C.: — In 1990, Mr. Bertrand lived in a two- bedroom apartment situated in the Byward Market neighbourhood in Ottawa. He received a promotion from his employer Tele-Direct Publications Inc. (Tele-Direct) which required him to move to

Christie J.T.C.C.: - This is an application by Carma Developers Ltd. (the “applicant”) under paragraph 58(1 )(a) of the Tax Court of Canada Rules (General Procedure) (the “Rules”). It, together with paragraph