Strayer, J.: —

MacKay, J.: —This matter, heard June 26, 1989 in Toronto, dealt with an application by the original respondent in this matter, the Satellite corporation, for return of an outstanding motion dated December 22, 1988, made pursuant to subsection 225.2(8)

Strayer, J.: —

Relief Requested

This is an appeal against the reassessments made by the Minister of National Revenue of the plaintiff's income tax for taxation years 1981, 1982, 1983, 1984 and 1985.

Marceau, J.A.: — This is an appeal against a judgment of Addy, J. of the Trial Division of this Court whereby, upon motion made by the defendant, Her Majesty the Queen, pursuant to rule 419(1)(a) [1] of the Federal

MacGuigan, J.A.: — Without necessarily endorsing all of the propositions of law adopted by the trial judge, we are nevertheless of the view that he made no error of law relevant to the result in the case at bar. Although the strict

Marceau, J.A.: —In spite of the able argument of counsel for the appellant, we have not been persuaded that the judge of first instance has committed any reviewable error in disposing of the case as he did. It may be that some of

Marceau, J.A.:—We are of the view that this appeal cannot succeed.

Reed, J.:—There are two main issues in this case. The first is whether subsection 225.1(5) of the Income Tax Act, (R.S.C. 1952, c. 148 as amended to February 25, 1987) requires that a taxpayer personally sign a letter of abeyance

Le juge Pinard: —Si vous aviez accepté l'offre d'ajournement que j'ai faite avant que vous ne commenciez à plaider pour prendre connaissance de l'arrêt Porter par le juge Joyal, vous vous seriez rendu compte à quel point cet arrêt-là est

Muldoon, J.: —The plaintiff appeals from reassessments of his income tax in regard to the taxation years 1977, 1978, 1979 and 1980. Although this appeal, which was heard in Saskatoon, Saskatchewan, proceeds by way of a trial de novo,