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

Sarchuk, T.C.J.:—Sass Manufacturing Limited appeals from reassessments of income tax for its 1981, 1982 and 1983 taxation years. These appeals raise two separate and distinct issues.

Couture C.J.T.C. [Translation] :—This appeal is from an assessment dated September 16, 1983 for the 1979 taxation year. In this assessment the respondent disallowed a deduction for inventory claimed by the appellant in computing its income in the amount of

Brulé T.C.J.: —