Brulé
T.C.J.
(orally):
Well,
Mr.
Fedak,
the
problem
is
that
without
any
kind
of
evidence
that
corroborates
what
you
have
told
us,
and
you
have
been
very
sincere
in
what
you
have
said
so
far,
but
I
find
that
you
have
not
made
a
case
that
involves
the
Income
Tax
Act,
when
the
Justice
Department
has
singled
out
that,
under
Section
63(3),
especially,
you
don’t
qualify.
And
all
I
can
say
is
that
with
that,
I
have
no
choice
but
to
dismiss
your
appeal.
Now,
having
said
that,
you
can
still
go
one
step
further
to
the
Federal
Court
of
Appeal,
and
then
you
may
be
better
qualified
to
have
a
record
or
keep
track
of
what’s
gone
on.
Because
this
is
the
problem
we
have.
Anybody
in
your
position
could
do
the
same
thing,
and
say,
“Let’s
get
rid
of
the
children
tonight,
and
we’ll
go
out
for
dinner.”
Now,
I
appreciate
you
haven’t
said
that,
and
you’re
not
implying
that’s
what
happened,
but
that
could
have
happened,
and
it
could
have
happened
with
lots
of
people.
And
so
I
don’t
have
any
corroborative
evidence.
Appeal
dismissed.
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