Bowman T.C.J.:

1 These appeals are from assessments for the 1990, 1991 and 1992 taxation years. Counsel agreed that the 1990 taxation year was representative of all three years and that the appeals for 1991 and 1992 would abide the result for 1990.

Bell T.C.J.:

The term “Appellant” herein refers to Vantem Holdings Ltd.