Strayer, J.:— This is an appeal from a decision of the Tax Court of Canada with respect to the reassessment by the Minister of National Revenue of the plaintiff's 1978 income.

Pratte J:—We do not need to hear you, Mr. McMechan.

Strayner, j.:—This is an appeal by the plaintiffs with respect to the reassessment by the Minister of their income tax in respect of 1981 and 1982. The Minister refused to allow them to deduct any of their losses with respect to the raising

Pinard, J. [Translation]:— By judgment dated July 24, 1986 the defendant was ordered to pay the plaintiff the sum of $291,301.05 with interest and costs.

Strayer, J.:—This is an appeal from a decision of the Tax Review Board dated February 10, 1981. It concerns reassessments made by the Minister of National Revenue of the plaintiff's income taxes in respect of 1973, 1974, and 1975.

MacGuigan, J.—This case reveals new wrinkles in the old cloth of income tax law, specifically with respect to the traditional problem of whether a sum of money has the quality of income or of capital. This kind of problem may arise either