Létourneau
J.:
The
Appellant
has
not
convinced
us
that
Dussault
J.
of
the
Tax
Court
of
Canada
has
made
any
error
which
justifies
our
intervention,
whether
it
is
in
respect
of
the
learned
judge’s
conclusions
of
fact
or
his
interpretation
and
application
of
the
law
to
these
facts.
Many
of
the
crucial
issues
to
be
decided
were
factual
in
nature
and
depended
heavily
on
the
credibility
of
the
witnesses.
The
Tax
Court
Judge
was
in
a
much
better
position
than
us
to
make
the
appropriate
findings
in
this
regard.
Consequently,
the
appeal
will
be
dismissed
with
costs.
Appeal
dismissed.
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