January 11, 1990
L.C. Tremblay Technical Interpretation
A/Director Division
Appeals and Referrals Division G.D. Middleton
957-9230
B. WheelerWilhelmus N. Nieuwenhuizen V. M.N.R. Adverse Decision - Tax Court of Canada
This is in reply to your memorandum of December 28, 1989 concerning the above noted adverse decision.
We agree that this decision should not be appealed to the federal court as there are no written reasons for the judgement and the decision is based solely on a finding of fact.
Bernhard Buetow Acting Director Technical Interpretations Division Legislative and Intergovernmental Affairs Branch
enclosures