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.

Jerome, A.C.J.:—This application by the plaintiff for an order that paragraph 167(5)(a) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72,

MacPherson, C.J.Q.B.:—This case raises the important question as to both the constitutionality and the Charter implications of subsection 224(1.2) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63), as amended (the

Scott, C.J.M.:- C.J.M.:—