Rip T.C.J.:

Décary J.A.:

This is another of those cases which involve, to use the words of my brother Robertson in À. v. Donnelly (1997), [1998] 1 F.C. 513 (Fed. C.A.) at 517 (leave to appeal denied by the Supreme Court of Canada, S.C.C. 26371 [reported (1998), 227 N.R. 282 (note) (S.C.C.)]), “taxpayers who earn their income in the city and lose it in the country”. The decision of the Tax Court Judge is reported at (1996), 97 D.T.C. 865 (T.C.C.) .