Giles A.S.P.:-The motion before me sought an order extending the time within which an appeal might be instituted pursuant to the provisions of subsection 167(4) of the Income Tax Act, R.S.C. 1985 (5th Supp.), c. 1 (the "Act"). The

Strayer J.A. (Décary, McDonald, JJ.A., concurring):—We are not persuaded that the learned motions judge made any reviewable error in the exercise of her discretion. The appeal will therefore be dismissed with costs.

Rowe D.J.T.C.C.:—The appellant appealed from an assessment dated December 8, 1986, assessing him for income taxes, interest and penalties in the sum of $103,463.32, payable by Pacific Refineries Inc. on the basis that at all material times the appellant was

Bonner, J.T.C.C.:—These are appeals from assessments under the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act") for the 1987 taxation year. The assessments were made on the basis that no part of the real

Hugessen J.A. (Robertson J.A. and Gray D.J. concurring):—The appellant appeals against two judgments (supported by a single set of reasons) rendered by McNair, J. in the Trial Division ([1990] 1 C.T.C. 196, 90 D.T.C. 6142). Those

Hugessen J.A.:—We have very little to add to what was said by the learned Tax Court Judge.

Hugessen J.A.:—The Crown has appealed from a judgment of the Trial Division allowing the respondent's appeal and reversing a decision of the Tax Court of Canada which had dismissed the appeal.

Strayer, J.:—

Hugessen, J.A. (orally):—We have not been persuaded that the learned trial judge erred in finding that the appellants’ financial adviser had “special knowledge" and that such special knowledge was the very foundation for the appel- lants’ acquisition and

Beaubier, J.T.C.C. (orally):— These appeals, pursuant to the General Procedure of this Court, were heard at Winnipeg, Manitoba on December 9 and 10, 1993.