Her Majesty the Queen and Minister of National Revenue v. F.C. Research Institute, 317966 Alberta Ltd. And First Canadian Holdings Ltd., [1990] 1 CTC 373, 90 DTC 6228 -- text
Mahoney, J.A.:—These appeals are from identical orders made by the Associate Chief Justice on applications of the respondent taxpayers, who claimed refunds of taxes they had not paid under Part VIII of the Income Tax Act. The reasons