Robertson
J.A.:
—
The
appellant
raises
two
issues.
The
second
need
not
be
addressed
if
we
conclude
that
the
Trial
Judge,
MacKay
J.,
did
not
err
in
deciding
that
the
respondent
is
not
liable
for
income
tax
under
Section
212
of
the
Income
Tax
Act.
We
so
conclude
and
for
the
reasons
given
by
the
learned
Trial
Judge.
Accordingly,
this
appeal
and
the
related
appeals
in
file
Nos.
A-420-94,
A-421-94
and
A-422-94
will
be
dismissed,
with
one
set
of
costs.
Appeal
dismissed.