MacGuigan, J.A.:—This is a case of statutory interpretation where a technological change has occurred after the passage of a statute. The statute in question is the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63)

MacGuigan, J.A.:—The issue in this case is one of tax timing: whether estimates of unbilled revenue at December 31, the end of the taxpayer appellant's taxation year, must be included in its income from business in that year.

Desjardins, J.A.:—This is an appeal from the judgment of the Trial Division (Addy, J.) which dismissed the appellants appeal from the denial of its application to the Minister of National Revenue (A.B. at 171) for a refund of federal consumption or

Hugessen, J.A.:—We have not been shown that Strayer, J. committed any reviewable error when he found as a fact that the payment of $1,370,000 received by the appellant from Imperial Oil in return for releasing the latter from its obligations for

Linden, J.A.:—This is an appeal by the Crown from a decision of the Associate Chief Justice, dated January 25, 1989, in which he decided in favour of the taxpayer in relation to two different reassessments for the 1978, 1979, 1980 and 1981

Garon, T.C.C.J.:—This is an appeal of an income tax assessment dated February 14, 1989, issued under subsection 224(4) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act") for failure to comply with

Beaubier, T.C.C.J.:—This matter was heard in Regina, Saskatchewan, on August 26, 1992. It is an appeal pursuant to the General Procedure of this Court respecting the appellant’s 1987, 1988 and 1989 taxation years.

Tremblay, T.C.C.J.:—Decision was reserved on this appeal on July 14, 1988. Evidence was heard on May 13,1987 in Montreal, Quebec, and written submissions were filed subsequently. The last information from the parties was received by the Court on July 14,

Tremblay, T.C.C.J.:—This appeal was heard on February 20 and May 9, 1991, in Montreal, Quebec.

Brulé, T.C.C J.:—This appeal involves the taxpayer's 1973 taxation year. The Minister of National Revenue ("Minister") assessed the appellant and included penalties on the basis that he failed to report income of $60,000 while the appellant maintains no