Pinard J.:—This is an appeal from an order of the prothonotary, dated November 23, 1994, which dismissed Howard D. Milne’s motion for a stay of execution proceedings.

The grounds of the appeal are:

Strayer J.A. (Décary, McDonald, JJ.A.):—

Giles A.S.P.:-The proceeding in which the motion before me is brought, arises because of an inquiry under section 231.4 of the Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.) (the "Act”), and seeks declarations that sections 231.4 and 5

LéTourneau J.A. (McGuigan and Robertson, JJ.A., :-Despite the forceful arguments of Mr. Adler who represented himself, we are of the view that the Tax Court judge committed no error of law in coming to the conclusion that the

Robertson J.A.:-This is an appeal from a decision of the Trial Division, [1992] 2 C.T.C. 214, 92 D.T.C. 6572 (F.C.T.D.), allowing an appeal by trial de novo from a decision of the Tax Court of Canada, [1989] 2 C.T.C. 2171, 89

Desjardins J.A.:-This appeal of a judgment of the Trial Division [1] relates to the interpretation of the word "processing" in the definition of "Canadian manufacturing and processing profits" for the purpose of calculating the manufacturing and

Rothstein J.:-The issue in this case is whether the words "the Minister shall reassess the taxpayer’s tax for any relevant taxation year...in order to take into account the deduction claimed" in subsection 152(6) of the Income Tax Act,

Joyal J.:-The plaintiff is appealing a decision rendered by the Tax Court of Canada which disallowed the deduction of the amounts in issue as business expenditures with respect to the 1984, 1985 and 1986 taxation years.

John A. Hargrave P.:-This motion, to stay realization proceedings under a writ of execution, arises out of an income tax debt for 1992 and 1993. The debt is the result of Howard D. Milne’ stock trading activities as a marketmaker on

Simpson J.:-The issue is whether Mr. Winston Penny, as a shareholder of a company, appropriated to himself an account receivable which was payable to the company. If he did so, the amount or value of that asset will be included in the computation