Robertson, J.A.:—These two appeals arise from a decision of a learned trial judge wherein he dismissed the appellants' appeals with respect to certain notices of assessment issued by the Minister of National Revenue. Pursuant to those notices, the appellants

lacobucci, |.:— We are all of the view that this appeal should be dismissed for the reasons given by Mr. Justice Linden of the Federal Court of Appeal. The expenses in question are clearly precluded by the provisions of subparagraph 18(1)(l)(i) of

Hugessen, J.A.:— We are all of the view that the learned trial judge committed no error when he looked at all the circumstances surrounding the making of the agreement between the appellant and his wife in order to determine that the payment

Linden, J.A.:—The issue on this appeal is whether a payment of money described as “interest” on a delayed settlement payment representing compensation for expropriated land should be characterized as interest and taxed as income, according to paragraph 12(1)(c) of

Dubé, J.:— The issue to be resolved in this tax case is whether a $40,000 gain on redemption of a Scientific Research Tax Credit debenture ("SRTC") ought to be treated as income or capital gain. This is the first case involving the SRTC

Isaac, C.J.:—This is an appeal from the order of a motions judge in the Trial Division dated November 8, 1991, allowing an appeal by the respondent made pursuant to Rule 336(5) of the Federal Court Rules from an order of the associate senior

Pratte, J.A.:— We are all of the view that this motion to quash must succeed.

It is common ground that this appeal must fail unless either one of the following two conditions are met, namely:

Rothstein, J.:—

Reed, J.:—The issue in this case is the proper interpretation of subparagraph 6(b)(i) [now 8(b)(i)] of Part XVII of Schedule III of the Excise Tax Act, R.S.C. 1970, c. E-13, as amended 1980-81-82-83, c. 68, section 40: