M.S.S. Inc. v. The Queen, 87 DTC 5088, [1987] 1 CTC 130, [1986] 2 CTC 99 (FCTD), aff'd 89 DTC 5502 (FCA) -- text
Pinard, J. [Translation]:—This is an appeal in the form of an action pursuant to subsections 172(1) and 175(3) of the Income Tax Act, SC 1970-71-72, c. 63, as amended, brought by the taxpayer M.S.S. Inc. against a decision of