| January 8, 1990 | |
| Appeals Branch | Technical Interpretations |
| Division | |
| L. Tremblay | F.B. Fontaine |
| Acting Director | 957-9228 |
| Appeals & Referrals Division |
Subject: 24(1) v MNR Tax Court of Canada
We have considered the Reasons for Judgment in respect of the above-noted case heard on November 7, 1989 and it is our view that the adverse decision should be appealed for the following reasons:
1.
2.
3. 24(1)
4.
Please note we have not reviewed the taxpayer's file. Our comments are based solely on the Reasons for Judgement given. Perhaps you will let us have the benefit of your views if this matter.
Bernhard BuetowActing DirectorTechnical Interpretations DivisionLegislative and Intergovernmental Affairs Division