Christie, A.C.J.T.C.:

1 What is in issue in these appeals is whether in reassessing Shell Canada Limited (“Shell”) regarding its liability to income tax the Minister of National Revenue (“the Minister”) erred

• (i) in disallowing $4,874,796 of the $15,519,491 interest deduction claimed by Shell in respect of its 1992 taxation year;

• (ii) in disallowing $1,675,643 of the $5,621,113 interest deduction claimed by Shell in respect of its 1993 taxation year; and

Tardif T.C.J.:

1 The appellant has appealed, under the informal procedure, from the assessments made by the Department of National Revenue (the “Minister”) for 1990, 1991 and 1992.

Rip T.C.J.:

1 On November 21, 1996 I heard motions by Owen Holdings Ltd., the appellant, and Her Majesty the Queen, the respondent. The genesis of the motions was orders issued by me on June 27, 1996, September 11, 1996 and September 26, 1996. The motions by the respondent were for orders, amongst other things, to stay or vary my order of June 27, 1996 by the motion by the appellant was to allow its appeal.

Watson D.J.T.C.:

1 This appeal was heard at Rimouski, Quebec on May 22, 1996.

• small business deduction (subsection 125(1) of the Income Tax Act (the “Act”)), $16,494;

• manufacturing and processing profits deduction (s. 125.1(1) of the Act), $495.

Beaubier T.C.J. (orally):

1 THE REGISTRAR: This is De Francesco for judgment. The time is 9:17.

2 HIS HONOUR: All right. This appeal, pursuant to the Informal Procedure, was heard at Toronto, Ontario at April 9, 1997. The Appellant was the only witness.

3 The Appellant has appealed the disallowance of his claim for a disability tax credit for his 1993 taxation year.

Linden J.A.:

Dussault T.C.J.:

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.