Canadian Reynolds Metals Co. Ltd. v. The Queen, 94 DTC 6340, [1994] 2 CTC 83 (FCTD), aff'd 96 DTC 6312 (FCA) -- text
Joyal, J.:—These consolidated appeals by the appellant against a number of tax reassessments raise a number of factual and legal issues and, in the course of the trial and of later interventions, have caused counsel for the parties and their witnesses to marshal much evidence and considerable argument. After all this, however, the parties will concede that there is not much conflict on the facts and debate centres generally on the application of various income tax rules to these facts.