Rouleau, J.: —In this case the plaintiff appeals an assessment of the Minister of National Revenue wherein excise tax and federal sales tax was levied on cooking wine imported by the plaintiff during the years 1986 and 1987.
Jerome, A.CJ.:—The respondents' applications by way of originating notice of motion for a review, pursuant to subsection 225.2(8) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act"), of my order dated
Heald, J.A. (Hugessen and MacGuigan, JJ.A concurring):—We have not been persuaded that the learned trial judge committed any reviewable error herein. In our view, the facts at bar simply do not establish a borrowing by the taxpayer so as to permit
Dubé, J.:—Le demandeur, un médecin radiologue de Montréal, Qc., réclame la somme de $18,270.14, à titre de remboursement d'impôt dû depuis le 3 juin 1980, qu'il allègue n'avoir jamais reçue.
Mahoney, J.A. (Stone and Desjardins, JJ.A., concurring):—This is an appeal from a reported decision of the Trial Division [[1989] 2 C.T.C. 128; 89 D.T.C. 5370] which granted the respondent a declaration that the Minister of National Revenue is not statute
Stone, J.A. (Heald and Linden, JJ.A., concurring):—The issue raised by this appeal is a narrow though important one. It concerns the interpretation to be given to the phrase "cost to the taxpayer” in subparagraph 54(a)(ii) of the Income Tax
Heald, J.A. (Stone and Linden, JJ.A., concurring):—This is a section 28 application to review and set aside the decision herein of Judge J.A. Brulé, a judge of the Tax Court of Canada dated March 15, 1991. In that decision Judge Brulé dismissed
Cullen, J.: —It is unfortunate that to date at least this Court has no jurisdiction to declare the plaintiff herein a vexatious litigant. Once again this plaintiff has abused the process of this Court, has made pleadings and arguments that are
Pratte, J.A.:—We have not been persuaded that Madame Justice Reed made any error in deciding as she did. The appeal will therefore be dismissed with costs.
Appeal dismissed.
Rouleau, J.:—This is an appeal by way of trial de novo from a decision of the Tax Court of Canada.
