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They are: …] find as a fact that the accused Bruce Relkie was the “directing mind” of the company respecting the filing of refund applications, in accordance with the identification theory of liability set out by the Supreme court of Canada in Canadian Dredge and Dock Company Ltd. v. ...

.: — Issue The issue in this appeal is whether the Appellant is subject to a penalty levied under subsection 163(2) of the Income Tax Act (“Act”) for his 1990, 1991 and 1992 taxation years. ...

.: — This is a motion by the Appellant for costs in connection with an application by the Minister of National Revenue (the “Minister”) to add a third party to the appeal herein. ...

.: — The Appellant elected, in her Notice of Appeal, wherein she appealed from her assessment of income tax for the years 1993 and 1994, the informal procedure. ...

.: — The appeals of Ronald Urquhart and June Urquhart are from assessments of tax with respect to the 1987, 1988, 1989, 1990 and 1991 taxation years. ...

.: — The assessment under appeal is a Notice of Assessment of Non-Resident Tax, number A355179, dated December 14, 1993. ...

.: — These are appeals by Andrew Bradbury (the Appellant) from assessments of tax with respect to his 1991 and 1992 taxation years. ...

.: — Grant Wilson (the “Taxpayer”) appeals a reassessment of his 1978 Income Tax Return on the basis that the Minister of National Revenue (“Revenue Canada”) failed to reassess with due dispatch following a notice of objection as required by subsection 165(3) of the Income Tax Act, S.C. 1970-71-72, c. 63 (the “Act”). ...

.: — In these appeals, which concern assessments for the 1991, 1992 and 1993 taxation years, the issue is the Minister of National Revenue’s refusal to allow the appellant a tax credit for a severe and prolonged mental or physical impairment pursuant to sections 118.3 and 118.4 of the Income Tax Act. ...

.: — This is an appeal from the assessments for the taxation years 1991, 1992 and 1993. ...