Fournier v. R., [1998] 2 C.T.C. 2001 -- text
Tardif T.C.J.:
1 The two appeals were heard on common evidence. These are appeals brought from assessments made by the respondent on October 19, 1993 and confirmed on June 9, 1995. The respondent relied on sections 3, 9, 10, 38, 39, 40 and 54 and subsection 248(1) of the Income Tax Act (the “Act”).