Heald, J.A. (Stone and MacGuigan, concurring):—This is a section 28 application to review and set aside the decision of Tax Court Judge D.W. Beaubier wherein he dismissed the application of this applicant, which was made pursuant to subsection 167(1) of

Rouleau, J.:—Mr. Jake Friesen is appealing the reassessments of business income by the Minister of National Revenue for the 1983 and 1984 taxation years.

Joyal, J.:—The plaintiffs appeal from Revenue Canada's tax reassessment for the year 1983 adding to their income certain benefits received by the plaintiffs from their employer, Turbo Resources Ltd. The nature of these benefits, taxable under paragraph 6(1)(a) of

MacGuigan J.A. (Heald and Linden, l].A., concurring.):—This case deals with an issue of tax timing similar to that recently decided by this Court in West Kootenay Power and Light Company Ltd. v.

Hugessen, J.A.:—The learned trial judge concluded that the appellant's dealings in the shares of Dome Petroleum were those of an investor for capital account rather than those of a trader or speculator. To reach this conclusion the judge weighed the

Hugessen, J.A.:— We are all of the view that the learned trial judge reached the correct result. The appellant would have us read subsection 13(7.1) [1] of the Income Tax Act, R.S.C. 1952, c. 148 (am.

Mahoney, J.A.:—We are in agreement with the interpretation the learned trial judge has placed on the term” reimbursement" in paragraph 12(1)(x)(iv) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act").

Cullen, J.:—This is an appeal from a reassessment of tax for the plaintiff's 1981, 1982, 1983 and 1984 taxation years. In the reassessment the Minister of National Revenue disallowed the amounts claimed by the plaintiff for the deduction of a reserve

Collier, J.:—This is an appeal, by the plaintiff taxpayer, in respect of income tax assessments issued by the Minister of National Revenue.

The Associate Chief Justice:—This appeal by way of trial de novo from a decision of the Tax Court of Canada dated September 25, 1986 came on for hearing at London, Ontario on October 1, 1991. The plaintiff appeals the