Isaac,
C.J.:—This
is
an
appeal
from
a
judgment
of
the
Trial
Division,
rendered
on
September
17,
1987,
which
allowed
the
respondent's
appeal
from
a
decision
of
the
Tax
Court
of
Canada.
By
that
decision,
the
Tax
Court
had
allowed
the
appellant's
appeal
of
a
notice
of
reassessment
issued
by
the
Minister
of
National
Revenue
which
had
included
the
sum
of
$48,055.10
in
the
appellant’s
income
for
the
taxation
year,
1981.
At
the
conclusion
of
the
trial,
the
learned
trial
judge
reviewed
conflicting
evidence
and
made
findings
of
credibility.
He
then
made
findings
of
fact,
based
upon
his
appreciation
of
the
evidence
which
he
accepted
and
he
concluded
that
the
amount
in
dispute
was
income
in
the
appellant's
hands
for
the
taxation
year,
1981.
We
are
all
of
the
view
that,
on
the
record
in
this
appeal,
the
Trial
Judge
made
no
palpable
or
overriding
error
in
reaching
his
conclusions
of
fact
and
that
those
conclusions
are
fully
supported
by
the
evidence.
Equally,
we
are
of
the
view
that
he
made
no
error
in
his
selection
of
the
legal
principles
applicable
to
the
case
before
him
or
in
applying
them
to
the
facts
as
he
found
them.
In
light
of
these
conclusions
and,
notwithstanding
the
thorough
arguments
presented
to
us
by
counsel
for
the
appellant,
we
are
all
of
the
view
that
this
appeal
should
be
dismissed
with
costs.
Appeal
dismissed.
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