LOCKE, J.:—The respondent was incorporated as a private company under the provisions of the Dominion Companies Act by letters patent issued on September 12, 1940, the capital stock consisting of five thousand shares without nominal or par value.

Dussault T.C.J.:

The first set of appeals (#96-19(IT)G) relates to assessments issued by the Minister of National Revenue (the “Minister”) under Part XIII of the Income Tax Act (the “Acf”) in respect of the 1988, 1989, 1990 and 1991 taxation years of Tonka Canada Inc. The appellant, Hasbro Canada Inc. (“Hasbro”) manufactures and distributes toys and games in Canada and is a successor company to Hasbro Canada Inc. and Tonka Canada Inc. which were amalgamated into the appellant with effect as of December 30, 1991.