Grant, DJ:—1. This is an appeal by the plaintiff in respect of the reassessments of its income tax for the years 1970 and 1971 made by the Minister of National Revenue on January 15, 1976 and on January 28, 1976, respectively.

The Associate Chief Justice:— This is an appeal under the Income Tax Act from a re-assessment of tax for the year 1973. In making the assessment the Minister disallowed as being an outlay of capital a deduction

Pratte, J:—In support of this appeal, the appellant’s counsel reiterated all the attacks that had been made in the Trial Division against his client’s income tax assessments for the years 1967 to 1975. In my view, all those attacks were rightly