Donald W. Kennedy v. Her Majesty the Queen, [1992] 2 CTC 59, 92 DTC 6380 -- text
Heald, J.:—We are in full agreement with the reasons given by the learned Tax Court judge for dismissing the taxpayer’s appeal. We think that he correctly applied the provisions of paragraph 227.1(2)(b) of the Income Tax Act, R.S.C.