Lamarre J.T.C.C.: — This appeal arises out of a determination by the Minister of National Revenue (the “Minister”) ascertaining the amount of the appellant’s non-capital loss for the taxation year ending December 31, 1982, to be $3,032,718. This determination

Mogan J.T.C.C.: —

Tremblay J.T.C.C.: — This appeal was heard in Québec, Quebec on January 10, 1995.

Bowman J.T.C.C.: — The question in this proceeding is the remedy, if any, that is available to the appellant under section 24 of the Canadian Charter of Rights and Freedoms in an appeal to this court under the

Archambault J.T.C.C.: — In 1978, François Prévost In (FPI) operated a real estate brokerage business in Québec. On November 27, 1978, that corporation submitted an offer to purchase the shares of Place Dalhousie Inc. (Dalhousie) to the

Bell J.T.C.C.: — Upon respondent’s motion for an Order pursuant to Rule 26 of the Tax Court of Canada Rules (General Procedure) to consolidate the within appeals, and upon hearing counsel for the parties, it is ordered that

Archambault J.T.C.C.: — Mr. Robert Huard, an attorney, did not file income tax returns for the years 1972 to 1982. In addition to income tax, the Minister of National Revenue (Minister) assessed penalties under subsection 163(1) of the

O’Connor J.T.C.C.: These appeals were heard in Toronto, Ontario on October 27, 1995 on common evidence pursuant to the informal procedure of this Court.

Bonner J.T.C.C.: — This is an appeal from an assessment of income tax for the 1987 taxation year. Booth Dispensers Limited (“Booth”) carried on the business of manufacturing soft drink dispensers. During its 1986 taxation year Booth “accrued” management

Sobier J.T.C.C.: — The appellant appeals from the assessments by the Minister of National Revenue (the “Minister”) whereby the Minister assessed the appellant pursuant to the provisions of subsection 160(1) of the Income Tax Act (the “Act”) in respect