Tomenson Inc. v. The Queen, 86 DTC 6267, [1986] 1 CTC 525 (FCTD), aff'd 88 DTC 6095, [1988] 1 CTC (FCA) -- text
Rouleau, J.:—This is an action brought by the plaintiff who disputes the reassessment by the defendant for the taxation year 1975. At issue in these proceedings is the nature of a payment made by the plaintiff in the amount of $322,461 for