Juda Rutenberg v. Minister of National Revenue, [1978] CTC 38, 78 DTC 6140 -- text
Marceau, J:—The appellant, a resident of the United States, is appealing the tax assessments made against him by the Minister on December 16 and 19, 1966 and July 8, 1971, pertaining to gains he is alleged to have made over the years 1955