Muldoon, J.:—This is a complicated income tax case which probably should never have had to be litigated. It has, however, been much litigated, in the following cases: R. v. Special Risk Holdings Inc., [1983] C.T.C. 36,

Décary, J.A.:—This is an application for judicial review pursuant to section 18.24 of the Tax Court of Canada Act of a decision rendered on November 18, 1991, by the Chief Judge of the Tax Court of Canada.

Donald, J.:—The issue remaining for decision in this petition, brought under paragraph 232(4)(c) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act"), as amended, relates to the claim of litigation or

Muldoon, J.:—The “plaintiff” herein has no solicitor of record, and no barrister or other counsel appeared with or for him at the hearing of this matter. That may account for the designations in the style of cause of "plaintiff" and "defendant" and

Dube, J.:—This application for judicial review under section 18.1 of the Federal Court Act, R.S.C. 1985, c. F-7, is for an order directing the Minister of National Revenue to allow the applicant taxpayer to carryforward his construction costs

Heald, J.A.:—Upon motion made by the appellant pursuant to Rule 324 of the Federal Court Rules, and upon reading the representations made by counsel for the appellant and the consent of counsel for the respondent, filed.

McKeown, J.:—The issues are whether the applicant has proven on a balance of probabilities that all three branches of the test in Manitoba Food & Commercial Workers, Local 832 v. Metropolitan Stores (MTS)

Alberstat, Master:—This is an application for advice and directions by the trustee of the estate of Rockton Shayne Bernard Neufeld.

Hugessen, J.A. (Pratte, Desjardins, JJ.A., concurring):—

Pratte, J.A. (Létourneau, McDonald, JJ.A., concurring):— This is an appeal from a judgment of the Canadian Tax Court allowing the respondent's appeal from its income tax assessment for the 1988 taxation year on the basis that, contrary to