Christie, ACJTC:—This appeal relates to the taxpayer's 1976 taxation year. The issue is whether it is entitled to deduct an inventory allowance in the amount of $652,754 in 1977 giving rise to a non-capital loss which it sought to carry back to

Rip, TCJ:—The appellants’ appeals from income tax assessments for 1976, 1977, 1978, 1979 and 1980 were heard on common evidence. The primary issue before the Court was to determine the value on December 31, 1971 of certain property located in Port

Esson, JA:—This appeal is by the defendant Continental Aerial Services Ltd against a judgment by which it was held liable for excise tax, pursuant to the provisions of the Excise Tax Act, RSC 1970, c E-13, in respect of the

Gratton, DCJ:—On consent of all parties, three questions have been submitted for the Court’s determination. They deal with the garnishability and exigibility of RRSPs generally, as well as with the rights of a beneficiary under an RRSP trust agreement and whether such rights are affected by seizure or garnishment.

McNair, J:—The sole issue in this income tax appeal is whether a person who is ordinarily resident in Canada by virtue of subsection 250(3) of the Income Tax Act is a taxpayer thas is deemed by section 250 of the Act to

Muldoon, J:—In order the better to conform with the rules and practices of this court, the style of cause in this action is amended to be that which is shown above.

Rouleau, J:—The plaintiff brings this action against the defendant by way of trial de novo. The Tax Review Board having set aside the reassessments by the Minister involving the taxation years 1978 and 1979. The issue concerns moneys deducted

Muldoon, J:—Because of the marked similarity of the facts in this case with those of The Queen v Jack L Salter, T-47-83, the two cases were tried together at Toronto, on September 25, 1985.

Muldoon, J:—Because of the marked similarity of the facts in this case with those of The Queen v William H Eggert,T-46-83, the two cases were tried together at Toronto, on September 25, 1985.

Addy, J:—The plaintiff is appealing its reassessment by the defendant for income tax purposes for the years 1978, 1979 and 1980.