Mahoney, J.A. (Robertson and McDonald, JJ.A., concurring):—This section 28 application seeks to set aside a decision of the Tax Court of Canada on an appeal from an income tax assessment conducted under its informal procedures. It

Denault, J.:—The plaintiff is appealing by way of trial de novo a judgment of Garon, T.C.C.J. of the Tax Court of Canada on July 13,1989 which maintained the defendant's appeal of notices of reassessment for the 1981 and 1982 taxation

Reed, J.:—The issue in this case is very narrow: whether a disposition occurred on June 1, 1985, as defined by paragraph 13(21)(c) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act").

Noël, J.:—This is an application by Her Majesty the Queen for a final order of garnishment against the garnishee, the Royal Bank of Canada. The judgment debtor objected to the application and made several arguments. One of them requires further consideration.

Mahoney, J.A. (Stone and McDonald, JJ.A. concurring):— This is an appeal from a reported decision of the Trial Division arising out of the assessment of the appellant's 1980 income tax return ([1986] 1 C.T.C. 418, 86 D.T.C.