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

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