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.

Jerome, A.C.J.:—In this action, the plaintiff appeals from two reassessments dated July 5, 1978 issued by the defendant in respect of the plaintiff's 1974 and 1975 taxation years.

Teitelbaum, J.:—The plaintiff, Rivermede Developments Ltd., appeals, by way of a trial de novo, from a decision of the Tax Court of Canada dismissing its appeal from a reassessment made by the Minister of National Revenue for the 1977 taxation year

Décary, J.A.:—This is an appeal from an interlocutory judgment of the Tax Court of Canada dismissing the appellant’s motion for leave to amend her amended reply to the notice of appeal for a fourth time. The motion was made on the fifth day