Isaacs,
C.J.:—In
this
section
28
application,
the
applicant
has
asked
this
Court
to
review
and
set
aside
a
decision
of
the
Tax
Court
pronounced
under
the
informal
procedure
in
subsection
18.15(4)
of
the
Tax
Court
of
Canada
Act,
R.S.C.
1985,
c.
T-2,
as
amended,
which
dismissed
the
applicant's
appeal
from
assessments
by
the
Minister
of
National
Revenue
of
her
income
tax
returns
for
the
taxation
years
1987
and
1988.
At
the
hearing,
the
applicant
raised
two
issues:
first,
that
the
learned
Tax
Court
judge
erred
in
law
in
dismissing
the
appeal
and,
secondly,
invoking
the
decision
of
this
Court
in
Muszka
v.
Canada,
[1994]
1
C.T.C.
365,
94
D.T.C.
6076,
that
he
erred
in
law
by
denying
the
applicant
the
opportunity
fully
to
present
her
case,
when
he
refused
to
allow
tne
applicant’s
husband,
who
was
also
acting
as
her
agent,
to
give
evidence.
The
second
issue
was
raised
only
after
Ms.
Van
Der
Hout,
counsel
for
the
respondent,
acting
according
to
the
highest
traditions
of
the
bar,
brought
Muszka,
supra,
to
the
attention
of
the
Court
and
the
applicant.
At
the
conclusion
of
argument
the
Court
reserved
its
decision,
being
then
of
the
view
that
extended
reasons
were
indicated.
However,
upon
consideration
of
the
submissions
made
to
us
by
the
applicant
who
was
unrepresented
by
counsel
and
by
counsel
for
the
respondent,
I
am
of
the
opinion
that
the
application
cannot
succeed,
for
the
short
reasons
that
follow.
With
respect
to
the
first
issue,
I
have
concluded
that
the
applicant
has
not
demonstrated
any
error
that
would
warrant
interference
by
this
Court.
Indeed,
in
my
opinion,
the
conclusion
of
the
learned
Tax
Court
judge
is
fully
supported
by
the
evidence
adduced
at
the
trial.
With
respect
to
the
second
issue,
it
is,
in
my
opinion,
sufficient
to
say,
upon
a
review
of
the
transcript
of
the
trial,
that
I
am
satisfied
that
the
applicant
was
not
denied
the
opportunity
fully
to
present
her
case
and
that
in
the
circumstances
of
this
case,
she
suffered
no
prejudice
by
reason
of
the
judge’s
refusal
to
allow
her
agent
to
give
sworn
evidence.
For
these
reasons,
I
would
dismiss
the
application.
Application
dismissed.
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