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

Mogan J.T.C.C.: — In this appeal for the 1992 taxation year, the only issue is whether a certain amount of $15,000 is required to be included in computing the appellant’s income. That amount was received in 1992 from her former husband in

Sobier J.T.C.C.: — The appellant elected to have his appeals, from the assessments of the Minister of National Revenue (the “Minister”) for his 1987 and 1989 taxation years, heard under the Informal Procedure.

McArthur J.T.C.C.: - These appeals were heard in Edmonton under the Informal Procedures of this Court with respect to the Appellant’s 1991 and 1992 taxation years.

Beaubier J.T.C.C.: This matter was heard at Vancouver, British Columbia pursuant to the General Procedure on September 15, 1995. The appellant (“Tetrad”) called James Wilson, its sole shareholder; Robert Moeller, C.A., its accountant; and Barbara English, Revenue Canada’s