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

Rouleau, J.:—In this action the plaintiff appeals the decision of the Associate Chief Justice of the Tax Court, dated January 18, 1990, which held that certain expenditures made by the plaintiff during its 1983 taxation year were payments made on account

MacGuigan, J.A. (Heald and Linden, JJ.A., concurring):—We are all agreed that the decisions of Pinard, J. at trial in these four related cases should be upheld.

Dubé, J.:—The issue to be resolved in these three actions heard together is whether or not the plaintiff was manufacturing or processing goods for sale under section 127 of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C.

Strayer, J.:—

Stone, J.A.:—This is an appeal from a judgment of the Trial Division rendered July 11, 1990, which allowed the appeal of the respondent from the reassessment of the Minister of National Revenue dated August 6, 1987, in respect of its 1982 taxation

Dubé, J.:—In a nutshell, the issue in this matter is whether the sum of $250,000 paid to the plaintiff was” on account of special management services" provided by it, as assumed by the defendant, or part of the proceeds of disposition of its

Hugessen, J.A.:—This is an appeal and a cross-appeal from a decision of McNair, J. rendered October 25, 1990. By that decision, the trial judge allowed in part the taxpayer's appeal from its assessments for the 1974 and 1975 taxation years.

Marceau, J.A.:— In spite of the able presentation of Mr. Henderson, we are of the view that this appeal cannot succeed. As we understand the analysis of subsection 31(1) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C.