Létourneau, J.A. (Marceau, Robertson, JJ.A concurring):— Pursuant to Rule 474 of the Federal Court Rules, the parties had submitted the following question of law for a determination:

Dubé, J.:— The instant application by the taxpayer is for an order that payment be made into Court respecting income tax certificate ITA-7628-92 dated September 30, 1992, and that Revenue Canada file a discharge of the certificate presently registered against

Hutchinson, J.:— The appellant, Harvard International Resources Ltd., (HIRL) appeals pursuant to subsection 50(2) of the Alberta Corporate Income Tax Act, R.S.A. 1980, c. A-17, (the “Alberta Act") from two decisions of the

Tallis, J.A.:— In these consolidated appeals, we are confronted with the constitutionality of the garnishment provision found in subsection 224(1.2) of the Income Tax Act, S.C. 1970-71-72, c. 63 [enacted 1987, c. 46 section 66; amended,

Morden, A.C.J.O., McKinlay and Catzman, JJ.A.:— This appeal by the Minister of Revenue concerns assessments made in respect of capital tax alleged to be payable by TransCanada Pipelines Limited for the years 1978 through 1981 pursuant to

MacGuigan, J.A.:— This is an appeal from a judgment of Martin, J. of October 11,1991, dismissing the appellant's appeal from income-tax reassessments for its 1977 to 1981 taxation years.

Mahoney, J.A.:— This is an appeal from a reported decision of the Trial Division ([1990] 2 C.T.C. 4, 90 D.T.C. 6335) arising out of a mistake made by the respondent in preparing his 1982 income tax return. The respondent elected to forward

MacKay, J.:—This is an appeal from a reassessment by the Minister of National Revenue, dated February 18, 1985, of the income tax return of the plaintiff corporation for its 1979 taxation year. Notice of objection to the reassessment was served on May 3, 1985.

Reed, J. (orally):— I am persuaded, in the circumstances of this case, that it is appropriate to stay the proceedings pending the final disposition of the defendant's motion for summary judgment.

Jerome, A.C.J.:— This is an appeal by the plaintiff from a decision of the Tax Court of Canada which dismissed his appeal from an assessment issued by the Minister of National Revenue on September 21, 1988.