Beaubier J.T.C.C.: — These matters were heard together on common evidence by consent of the parties on February 1 and 2, 1996 at Vancouver, British Columbia. Both Appellants testified. The Appellants called an expert psychiatrist, Dr. Kerr.
Sarchuk J.T.C.C.: - This is an appeal by Odyssey Industries Incorporated from an assessment of tax with respect to its 1985 taxation year.
The parties admit the following facts:
Taylor J.T.C.C.: — These are appeals heard in Toronto, Ontario, on December 12, 1995, under the informal procedure, against income tax assessments for the years 1989, 1990, 1991 and 1992 in which the Respondent disallowed claims for losses sustained
Couture C.J.T.C.C.: — This is an appeal pursuant to the rules of the informal procedure from an assessment issued by the respondent under subsection 224(4) of the Income Tax Act, the “Act”. The relevant legislation reads:
Rip J.T.C.C.: — Redclay Holdings Limited (“Redclay”) appeals from an income tax assessment of its 1988 taxation year and determinations of losses by the Minister of National Revenue (“Minister”) in respect of its 1986 and 1987 taxation years. The issues
Bowman J.T.C.C.: — These appeals are from assessments for the appellant’s 1990 and 1991 taxation years. The issue is the deductibility of interest paid on loans made to the appellant by Niagara Credit Union Limited. The purpose of the loans was
Tremblay J.T.C.C.: — This appeal was heard on November 15, 1995, at Montreal (Quebec).
O’Connor J.T.C.C.: — This appeal was heard in Regina, Saskatchewan on January 18, 1996 pursuant to the Informal Procedure of this Court.
Brulé J.T.C.C.: — This appeal involves a reassessment of the Appellant’s 1990 taxation year. It is to be determined on the basis of whether or not the Appellant who disposed of certain shares in 1990 suffered an income loss rather than a
Bell J.T.C.C.: — The Appellant has appealed the reassessment of its 1988 taxation year ending December 31, 1988. The Minister of National Revenue (“Minister”), in reassessing, treated the sums of $59,523,409 and $23,232,706 (totalling $82,756,115) as proceeds of
