Beaubier T.C.J.:

1 This appeal pursuant to the Informal Procedure was heard at Vancouver, British Columbia, on January 7, 1997. The Appellant was the only witness.

2 The Appellant claimed to deduct business losses for 1992, 1993 and 1994. They were denied. He appealed.

Taylor T.C.J.:

1 This is an appeal heard in Toronto, Ontario, on December 3, 1996, against income tax assessments for the years 1992 and 1993. The essential elements of the Notice of Appeal, and the Reply to the Notice of Appeal are as follows:

Notice of Appeal

Material Facts

1. In 1992 and 1993 the Appellant duly reported his income for the 1992 and 1993 taxation years.

Beaubier T.C.J.:

1 These appeals pursuant to the General Procedure were heard together on common evidence by consent of the parties at Calgary, Alberta on February 25 and 26, 1998.

Tardif T.C.J.:

1 The point at issue is whether the appellant was entitled to the child tax benefit for July and August 1993. The respondent claims that the benefit was payable to the child's father, relying in particular on sections 122.6 to 122.64 and subsection 248(1) of the Income Tax Act (the “Act”) and sections 6300, 6301 and 6302 of the Income Tax Regulations (the “Regulations”).

Rip T.C.J.:

Bowman T.C.J.:

1 These appeals were heard together on common evidence and concern the 1988 and 1989 taxation years.

Richard Morneau P.:

1 This is an ex parte motion by the judgment creditor (the creditor) for an order of this Court that this matter proceed in accordance with the rules governing actions.

McArthur T.C.J.:

1 These appeals were heard in Halifax on common evidence for the years 1988, 1989 and 1990. The Minister of National Revenue (the “Minister”) included in the Appellants' respective incomes, for each year, amounts paid to two trusts funds. The Appellants' sons were the sole beneficiaries of these trust funds. The money was advanced by way of dividends paid to the trusts by Brimar Developments Ltd. (Brimar) which was a corporation controlled by the Appellants.

Isaac C.J.:

1 This is an application for judicial review of a judgment of the Tax Court of Canada dated 17 May, 1996 dismissing the appellant's appeal from assessments made by the Minister of National Revenue under the Income Tax Act (“the Act”) for the years 1989 and 1990.

2 For the reasons that follow we are all of the view that the application cannot succeed.

Bowie T.C.J.: