Desjardins J.A.:

We are of the view that these appeals must fail.

Noel J.A.:

Pratte J.A.:

Décary J.A.:

The main issue in this appeal from a decision of the Tax Court of Canada[1] is the appellant golf club’s tax exemption in respect of income from sources other than property under subparagraph 149(5)(^)(i) of the Income Tax Act, R.S.C. 1985 (5th Suppl.), c. 1, as amended (“the Act”), on the basis that it is a non-profit organization “the main purpose of which is to provide dining, recreational or sporting facilities for its members” (a “club”).

Pinard J.:

Noel J.A.:

Evans J.:

Strayer J.A.:

The appellant has not demonstrated any error in the decision of the Tax Court Judge to strike the notice of appeal because it disclosed no reasonable grounds for appeal. This appeal will therefore be dismissed.

Strayer J.A.:

This is an appeal from a judgment of the Tax Court of Canada. It concerns the characterisation of certain moneys paid by the appellant to holders of its debentures in the course of buying back those debentures.

Strayer J.A.:

We are all of the view that the appellant’s constitutional argument cannot succeed.