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

Lamarre Proulx J.T.C.C.: — These are appeals concerning the 1988, 1989 and 1990 taxation years of the Appellant.

Bonner J.T.C.C.: — This is an appeal from an assessment of income tax for the 1992 taxation year. In his return of income for that year the appellant claimed to deduct $30,768 as an allowable business investment loss (“ABIL”). The deduction

Teskey J.T.C.C.: — The Appellant elected to have his appeal from assessment of income tax for the year 1992 heard pursuant to the informal procedure.

Garon J.T.C.C.: - These Reasons deal with the Respondent’s motion (the “main motion”) and the Appellant’s cross-motion in two income tax appeals. Both motions were heard at the same time.

Bowman J.T.C.C.: - In this appeal from an assessment for the appellant’s 1984 taxation year, two issues are raised:

Teskey J.T.C.C.: — The Appellant appeals from assessments of income tax for the years 1988, 1989 and 1991.

Christie A.C.J.T.C.C.: — The appellant appeals from reassessments made against him on a net-worth basis for the 1988, 1989, 1990 taxation years. In reassessing, the Minister of National Revenue (“the Minister”) added these amounts to the appellant’s total

Teskey: — The Appellant appealed his assessment of income tax for the years 1987, 1988 and 1989.

Rip J.T.C.C.: — Each of David McVey and Heather Perkins-McVey, husband and wife respectively, have appealed assessments for income tax levied under subsection 160(1) of the Income Tax Act (“Act”). The notices of assessment, dated