Stone J.A.:

1 This is an appeal from a judgment of the Tax Court of Canada of January 19, 1996[FN1: <p>The case is now fully reported as<em>Cargill Ltd. v. R.</em>, [1996] 2 C.T.C. 2102 (T.C.C.).</p>] The case at trial was heard on an agreed statement of facts and on oral evidence. The appellant called one expert witness, and a witness was called by the respondent. The facts are not in dispute.