MaGuigan,
J.A.:—We
have
not
been
persuaded
that
the
Tax
Court
judge
committed
any
reviewable
error.
It
may
well
be,
as
the
applicant
alleged
before
us,
that
evidence
could
have
been
presented
which
would
have
disproved
the
assumptions
of
Revenue
Canada,
but
he
chose
not
to
present
that
evidence,
apparently
in
order
to
limit
his
expenses
of
litigation.
The
applicant
cannot
now
be
allowed
to
reproach
the
Tax
Court
judge
for
having
decided
the
matter
against
him
on
the
only
evidence
actually
before
the
Court.
The
section
28
application
must
therefore
be
dismissed.
Application
dismissed.
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