Taylor, T.C.J.:—This is an appeal heard in Toronto, Ontario on March 21 and 22, 1988, against an income tax assessment for the year 1982. The following agreed statement of facts sets out the dispute:
Brulé, T.C.J.:—The appellant is objecting to an assessment of her 1981 income tax return in which she showed a capital gain, which amount was adjusted lower by Revenue Canada, but which the appellant later said the subject shares of the capital
Brule, T.C.J.: —By notice dated September 3, 1986 the Minister assessed the appellant under subsection 227.1(1) of the Income Tax Act ("Act") for tax and penalty, and interest thereon in the amount of $24,772.02 in respect of
