Marceau
J.A.:
We
are
all
of
the
view
that
this
application
cannot
succeed.
It
is
clear
to
us
that
the
issue
to
be
resolved
by
the
Tax
Court
of
Canada
judge
involved
only
an
assessment
of
facts.
Once
the
facts
were
established,
the
application
of
the
law
did
not
present
any
difficulties.
With
regard
to
the
facts,
there
is
nothing
to
suggest
that
the
judge
assessed
the
evidence
or
interpreted
the
testimony
he
heard
in
a
perverse
or
capricious
manner.
By
stating,
as
he
did,
that
the
applicant
had
not
managed
to
convince
him
that
the
Minister’s
allegations
were
false,
which
would
have
been
necessary
for
him
to
reject
them,
the
judge
was
ruling
as
he
was
required
to
do
and
his
conclusion
must
be
respected.
The
application
must
be
dismissed.
Appeal
dismissed.
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