Cullen, J.: —No evidence was called. The parties hereto filed an agreed statement of facts as follows:

Denault, J.: —This is an appeal by way of statement of claim, pursuant to subsection 172(2) of the Income Tax Act, from notices of reassessment for the 1978, 1979, 1980 and 1981 taxation years, restricting losses from the plaintiff's

Strayer, J.:

Strayer, J.:

Lacombe, J.:—This is an application made by the applicant under Rule 346(2) for review of the taxation of the respondent's bill of costs in this Court, as a result of the dismissal with costs of the applicant's appeal on the merits of this

Cullen, J.:— This is an appeal from a reassessment of tax for the plaintiff's 1980 taxation year. In this reassessment the Minister of National Revenue, (Minister) disallowed amounts deducted on account of cargo claims and fines paid under the

Heald, J.: —The learned Tax Court judge decided that, in an application such as this, the applicant carries the onus of showing that it would be just and equitable to grant the extension of time sought and that the application was brought

Pratte, J.:—With respect to the two main issues raised on this appeal, despite Mr. Pitfield’s able argument, we are in full agreement with the reasons of the trial judge.

Urie, J.: —This application pursuant to section 28 of the Federal Court Act seeks to set aside a judgment rendered by the Associate Chief Judge of the Tax Court of Canada, in which he held that issue estoppel based on

Pratte, J.: —We are all of the opinion that the decision of the Trial Division cannot be reconciled with the recent judgment of this Court in The College of Physicians and Surgeons of British Columbia