| February 12, 1990 | |
| To: Head Office | From: Technical Interpretations |
| Appeals Branch | Division |
| G.D. Middleton | |
| Attention: L.C. Tremblay | Tel. (613) 957-9230 |
| A/Director | |
| Appeals and Referrals Division | File No. 90M02253 |
Subject: A.C. Simmonds & Sons Ltd. - Adverse Decision of Tax Court of Canada
We are replying to J. Yu's memorandum of January 23, 1990 concerning the above mentioned adverse decision.
We agree with the recommendations of your Branch that his decision should not be appealed to the Federal Court since the judgement is based on a finding of fact and is not contrary to the law.
Bernhard BuetowDirectorTechnical Interpretations DivisionLegislative and Intergovernmental Affairs Branch
SP/hm(19) Cor"A"