Heald, J.:—This appeal from a judgment of the Trial Division relates to assessments of the appellant by the Minister of National Revenue (the Minister) for income tax for the taxation years 1981 and 1982. The issue between the parties is the

Hughes, J.:—The respondents were charged jointly on December 3, 1986 with one count of unlawfully evading the payment of income tax and three counts of unlawfully making false or deceptive statements in Print Three Inc’s income tax returns, contrary to