Per
Curiam:
Despite
the
valiant
efforts
of
Mr.
Ruby
for
the
applicant,
we
have
not
been
persuaded
that
the
learned
Tax
Court
Judge
made
any
error
that
warrants
our
intervention.
The
section
28
application
will
therefore
be
dismissed.
Application
dismissed.
[1998]
1
C.T.C.
Tax
Court
Decisions