Sarchuk T.C.J.:

1 This is an appeal by Eric John (the Appellant) from an assessment of tax with respect to his 1994 taxation year. At issue is the proper application of subsection 118(2) of the Income Tax Act (the Act).

Robertson J.A.:

Lamarre Proulx T.C.J.:

1 These are appeals, heard under the informal procedure, from reassessments made using the net worth method for 1989, 1990 and 1991.

2 The issues concern the accuracy of the calculation of the net worth difference and the imposition of penalties pursuant to s. 163(2) of the Income Tax Act (“the Act”) for each of the years on appeal.

Tanasychuk T.O., T.C.C.:

Gibson J.:

Gibson, J:

1 These four appeals were heard on common evidence.

Gibson, J:

1 These appeals were heard seriatim, and certain of the evidence by agreement was common to both.

2 The appeals in both cases are from reassessments for the taxation years 1958 and 1959 of each of the appellants.

The Chief Justice (orally for the Court):

1 Nous sommes tous d'opinion que le pourvoi est mal fondé et doit être rejeté avec dépens. Le pourvoi est rejeté avec dépens.

The Assistant Chairman:

1 This is the appeal of Cecil M Langille from an income tax assessment in respect of the 1972 taxation year which was heard in London, Ontario on September 29, 1975.

2 The issue, as I understand it, is that the appellant, having made no deduction from his income for premiums paid into a registered retirement savings plan, objects to being taxed on the return of his capital in the form of annuity payments.

The Assistant Chairman:

1 This is the appeal of Greensteel Industries Ltd from an income tax reassessment in respect of the appellant's 1970 taxation year.

2 By notice of reassessment dated September 12, 1972, the Minister of National Revenue disallowed in the appellant's 1970 taxation year an amount of $100 being that portion of what the appellant claims to be a deductible business loss of $52,107.30 and which the Minister assumes to be a capital loss.