Lamarre Proulx J.T.C.C.:—This appeal is about a penalty imposed pursuant to subsection 162(2) [1] of the Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.) (the ’’Act") for the year 1990.

Lamarre J.T.C.C.:-This appeal arises out of a disallowance by the Minister of National Revenue (the ’’Minister") of certain deductions claimed by the appellant as current business expenses for the 1985, 1988 and 1989 taxation years.

Mogan J.T.C.C.:—The appellant is a corporation existing under the laws of the Province of Ontario. Its principal business is the development and operation of commercial office buildings in Canada. The appellant has a number of subsidiary corporations in the

Brulé J.T.C.C.:-This appeal is in respect of the deduction of farm losses incurred by the appellant during his 1990 taxation year in the amount of $26,548. The Minister of National Revenue (the ’’Minister”) disallowed the appellant’s claim by restricting his loss

McArthur J.T.C.C.:-This appeal was heard in Sudbury under the informal procedures of this Court with respect to the appellant’s 1991 taxation year. The respondent disallowed the appellant’s claim for non- refundable disability tax credit in the amount of $4,118.

Teskey J.T.C.C.:—Both appellants herein appeal from assessments of income tax for the 1987 and 1988 taxation years. These appeals were heard on common evidence.

Issues

Originally there were three issues, namely:

Mogan J.T.C.C.:-The appellant is a farmer who operates a mixed farm, but primarily a dairy farm, about 15 miles from Westlock, Alberta, which is about 45 miles northwest of Edmonton. The appellant sells all of his milk product to Northern Alberta Dairy

Beaubier J.T.C.C.:-This matter was heard at Ottawa, Ontario on November 15, 1994 pursuant to the rules of general procedure of this Court. The appellant called Peter Doody, an Ottawa lawyer who represented the appellant in civil litigation which will be described.

Garon J.T.C.C.:— This is an appeal from an income tax reassessment dated November 10, 1993, made by the Minister of National Revenue (the "Minister") in respect to the 1991 taxation year. By his reassessment, the Minister included in the appellant’s

Christie A.C.J.T.C.:—This appeal is governed by the informal procedure prescribed by section 18 and following sections of the Tax Court of Canada Act.