Isaac
C.J.:-We
are
all
of
the
view
that
there
was
evidence
to
support
the
finding
of
the
learned
trial
judge
that
the
appellant
did
not
make
a
reasonable
attempt
to
correctly
determine
its
capital
surplus
on
hand
as
required
by
subsection
184(3.1)
of
the
Income
Tax
Act,
R.S.C.
1985,
c.
1
(5th
Supp.)
(the
"Act")
and
that
there
is
no
legal
basis
for
interference
by
this
Court
with
that
conclusion.
In
view
of
the
conclusion
we
have
reached
on
that
issue
we
do
not
find
it
necessary
to
express
any
opinion
on
the
second
issue
raised
by
the
appellant.
We
will
therefore
dismiss
the
appeal
with
costs.
Appeal
dismissed.
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