Maher,
J:
—In
these
matters
three
applications
are
made
for
a
determination
as
to
whether
the
actions
by
The
Minister
of
National
Revenue
(hereinafter
referred
to
as
"the
Minister”),
directing
that
the
applicant
taxpayers
forthwith
pay
the
amounts
of
certain
assessments
of
income
tax
were
justified
in
the
circumstances.
The
applications
are
pursuant
to
subsection
225.2(2)
of
the
Income
Tax
Act,
R.S.C.
1952,
c.
148,
as
amended
by
S.C.
1970-71-72,
c.
63
and
subsequent
amendments.
Following
an
order
fixing
a
day
and
place
for
the
determination
of
the
question,
the
applications
were
heard
together
by
agreement
of
counsel
and
reserved
for
decision.
The
section
under
which
the
applications
are
made
was
recently
enacted,
along
with
other
amendments
to
the
Income
Tax
Act
that
limit
the
authority
of
the
Minister
to
enforce
payment
of
taxes
owing
on
an
assessment
until
there
had
been
a
final
determination
as
to
the
amount
of
tax
payable.
S.C.
1985
c.
45,
s.
116.
By
these
amendments
the
right
of
the
Minister
to
take
steps
to
collect
a
tax
assessed
under
the
Act
is
restricted
in
various
ways.
No
enforcement
proceedings
may
be
commenced
for
a
period
of
90
days
following
the
mailing
of
a
notice
of
an
assessment.
Where
the
taxpayer
serves
a
notice
of
objection
to
the
assessment
no
enforcement
proceedings
may
be
taken
until
90
days
following
the
confirmation
or
variation
of
the
assessment.
In
the
event
of
an
appeal
enforcement
proceedings
are
prohibited
until
the
appeal
has
been
decided.
Notwithstanding
these
limitations
"where
it
may
reasonably
be
considered"
that
collection
of
an
amount
assessed
in
respect
of
a
taxpayer
would
be
jeopardized
by
a
delay
in
the
collection
thereof,
the
Minister
may,
by
notice
in
writing,
direct
the
taxpayer
to
forthwith
pay
the
amount
assessed.
The
taxpayer,
in
turn,
following
receipt
of
such
notice,
may
apply
to
the
Court
for
the
determination
of
the
question
whether
the
direction
was
justified
in
the
circumstances.
While
I
have
outlined
in
general
terms
the
steps
that
may
be
taken
by
the
Minister
and
a
taxpayer
it
may
be
of
assistance
to
set
out
in
full
the
provisions
of
section
225.2.
It
reads
as
follows:
225.2(1)
Collection
in
jeopardy.
—
Notwithstanding
section
225.1,
where
it
may
reasonably
be
considered
that
collection
of
an
amount
assessed
in
respect
of
a
taxpayer
would
be
jeopardized
by
a
delay
in
the
collection
thereof,
and
the
Minister
has,
by
notice
served
personally
or
by
registered
letter
addressed
to
the
taxpayer
at
his
latest
known
address,
so
advised
the
taxpayer
and
directed
the
taxpayer
to
pay
forthwith
the
amount
assessed
or
any
part
thereof,
the
Minister
may
forthwith
take
any
of
the
actions
described
in
paragraphs
225.1(1)(a)
to
(g)
with
respect
to
that
amount
or
that
part
thereof.
(2)
Application
to
vacate
direction.
—
Where
the
Minister
has
under
subsection
(1)
directed
a
taxpayer
to
pay
an
amount
forthwith,
the
taxpayer
may
(a)
upon
3
days
notice
of
motion
to
the
Deputy
Attorney
General
of
Canada,
apply
to
a
judge
of
a
superior
court
having
jurisdiction
in
the
province
in
which
the
taxpayer
resides
or
to
a
judge
of
the
Federal
Court
of
Canada
for
an
order
fixing
a
day
(not
earlier
than
14
days
nor
later
than
28
days
after
the
date
of
the
order)
and
place
for
the
determination
of
the
question
whether
the
direction
was
justified
in
the
circumstances:
(b)
serve
a
copy
of
the
order
on
the
Deputy
Attorney
General
of
Canada
within
6
days
after
the
day
on
which
it
was
made;
and
(c)
if
he
has
proceeded
as
authorized
by
paragraph
(b),
apply
at
the
appointed
time
and
place
for
an
order
determining
the
question.
(3)
Time
for
application.
—
An
application
to
a
judge
under
paragraph
(2)(a)
shall
be
made
(a)
within
30
days
after
the
day
on
which
the
notice
under
subsection
(1)
was
served
or
mailed;
or
(b)
within
such
further
time
as
the
judge,
upon
being
satisfied
that
the
application
was
made
as
soon
as
circumstances
permitted,
may
allow.
(4)
Hearing
in
camera.—
An
application
under
paragraph
(2)(c)
may,
on
the
application
of
the
taxpayer,
be
heard
in
camera,
if
the
taxpayer
establishes
to
the
satisfaction
of
the
judge
that
the
circumstances
of
the
case
justify
in
camera
proceedings.
(5)
Burden
to
justify
direction.
—
On
the
hearing
of
an
application
under
paragraph
(2)(c)
the
burden
of
justifying
the
direction
is
on
the
Minister.
(6)
Disposition
of
application.
—
On
an
application
under
paragraph
2(c)
the
judge
shall
determine
the
question
summarily
and
may
confirm,
vacate
or
vary
the
direction
and
make
such
other
order
as
he
considers
appropriate.
(7)
Continuation
by
another
judge.
—
Where
the
judge
to
whom
an
application
has
been
made
under
paragraph
(2)(a)
cannot
for
any
reason
act
or
continue
to
act
in
the
application
under
paragraph
(2)(c),
the
application
under
paragraph
(2)(c)
may
be
made
to
another
judge.
(8)
Costs.
Costs
shall
not
be
awarded
upon
the
disposition
of
an
application
under
subsection
(2).
It
should
be
noted
that
two
of
the
applicants
are
individuals
and
the
third
is
a
corporation.
The
position
of
the
Minister
is
that
because
the
individuals
are
related,
being
a
father
and
son,
and
that
the
corporation
R.
&
L.
Investments
Ltd.,
together
with
at
least
three
other
corporations,
are
controlled
by
members
of
the
same
family,
both
the
individuals
and
the
corporations
are
“related
persons"
as
defined
by
section
251
of
the
Act.
Accordingly,
they
are
deemed
not
to
deal
with
each
other
at
arm's
length.
The
relationships
are
not
disputed
by
the
applicants.
Extensive
investigations
were
conducted
into
the
activities
of
both
the
individuals
and
the
related
corporations.
The
results
of
such
investigations
are
set
out
in
reports
prepared
for
the
purpose
of
recommending
jeopardy
assessments
in
each
of
the
three
cases,
and
copies
of
such
reports
with
respect
to
each
application
have
been
filed
and
were
made
available
to
the
applicants.
It
is
not
my
intention
to
review
the
reports
in
detail
but
I
consider
it
necessary
to
summarize
the
facts
as
they
are
set
forth
in
the
reports,
not
only
in
so
far
as
they
relate
to
the
taxpayers
assessed,
but
also
to
other
members
of
the
family
and
to
corporations
that
are
not
the
subject
of
these
proceedings
but
are
related
and
not
deemed
to
be
at
arm's
length.
Involved
in
various
transactions
that
have
taken
place
over
a
number
of
years
are
four
members
of
the
Minshull
family,
Robert
Minshull,
his
wife
Marion,
and
their
two
sons,
Lawrence
and
Raymond
Minshull.
The
corporations
involved
are
the
applicant
R.
&
L.
Investments
Ltd.,
Bridge
City
Properties
Ltd.,
Marion
Minshull
Enterprises
Ltd;
and,
to
a
lesser
extent,
Sunset
Bay
Resorts
Inc.
All
the
corporations
would
appear
to
be
solely
owned
and
controlled
by
the
four
members
of
the
Minshull
family.
It
is
not
disputed
that
the
first
three
corporations
have
failed
to
file
income
tax
returns
for
a
number
of
years.
The
last
return
filed
on
behalf
of
R.
&
L.
Investments
Ltd.
was
for
the
taxation
year
1982,
for
Bridge
City
Properties
Ltd.,
for
the
taxation
year
1980,
and
for
Marion
Minshull
Enterprises
Ltd.,
for
the
taxation
year
1979.
The
assessments
of
income
tax
against
the
applicants
are
for
substantial
amounts.
They
include
assessments
made
pursuant
to
section
160
of
the
Act,
whereby
both
the
transferor
and
the
transferee
of
property
by
persons
or
corporations
not
dealing
at
arm's
length
are
equally
liable
for
any
tax
liability
arising
by
reason
of
any
such
transaction.
The
assessments
made
against
the
applicants
and
for
which
the
Minister
seeks
the
right
to
enforce
payment
forthwith
are
as
follows:
Robert
R.
Minshull
Section
160
Assessment.
Transfers
from
Marion
Minshull
Enterprises
Ltd.
in
the
year
1983
$92,265.00
Section
160
Assessment.
Transfers
from
R.
&
L.
Investments
Ltd.
in
the
year
1986
$96,612.93
Lawrence
R.
Minshull
Section
160
Assessment.
Transfers
from
Bridge
City
Properties
Ltd.
in
the
year
1984
$25,194.08
Section
160
Assessment.
Transfer
from
Marion
Minshull
Enterprises
Ltd.
in
the
year
1984
$39,000.00
R.
&
L.
Investments
Ltd.
Section
160
Assessment.
Property
transfers
from
Bridge
City
Properties
Ltd.
in
the
year
1984
$25,194.08
Income
Tax
Assessment
for
the
taxation
year
1984
$94,294.89
Income
Tax
Assessment
for
the
taxation
year
1985
$99,004.27
In
addition
to
the
foregoing,
arbitrary
assessments
were
previously
made
against
both
R.
&
L.
Investments
Ltd.
and
Bridge
City
Properties
Ltd.
in
the
year
1985,
likely
by
reason
of
the
fact
that
both
corporations
had
ceased
to
file
income
tax
returns.
Probably
for
the
same
reason,
along
with
the
fact
that
the
amounts
assessed
had
not
been
paid,
the
Minister,
in
the
summer
of
1986,
served
Requests
for
Information
on
a
number
of
brokerage
firms
in
the
City
of
Saskatoon,
and
also
served
Requirements
to
Pay
on
several
financial
institutions.
These
demands
for
information
and
payment
were
made
with
respect
to
all
three
of
the
applicants.
The
service
of
these
documents
triggered
acts
on
the
part
of
the
applicants
that
are
not
without
significance.
Apparently,
the
investment
account
of
R.
&
L.
Investments
Ltd.
with
Midland
Doherty
Limited
was
not
attached
by
the
Minister,
but
within
five
days'
service
of
the
documents
on
other
financial
institutions,
the
entire
balance
to
the
credit
of
the
R.
&
L.
Investments
Ltd.
account
totalling
$41,900
was
withdrawn
by
cheques
payable
to
Robert
Minshull
personally.
The
requests
for
information
also
revealed
that
the
account
of
R.
&
L.
Investments
Ltd.
with
the
Bank
of
Nova
Scotia
has
not
been
used
by
that
company
since
it
was
attached
by
the
Minister
and
no
new
banking
source
for
the
company
has
been
ascertained.
Additional
information
received
by
the
Minister
following
service
of
the
requirements
for
information
revealed
that
in
March
1986
the
sum
of
$22,719.33
was
withdrawn
from
the
investment
account
of
R.
&
L.
Investments
Ltd.
with
Midland
Doherty
Limited
by
Robert
Minshull
and
transferred
to
the
credit
of
a
coin
auction
company
in
London,
England.
This
was
preceded
by
a
withdrawal
of
$92,265.00
from
the
investment
account
of
Marion
Minshull
Enterprises
Ltd.
with
Midland
Doherty
Limited
in
the
year
1983.
It
is
admitted
by
the
applicants
that
both
these
sums
were
used
for
the
puchase
of
rare
Canadian
sovereigns
in
the
name
of
a
syndicate
owned
and
controlled
by
members
of
the
late
[sic]
Minshull
family,
the
various
companies
operated
by
the
Minshull
family,
and
four
other
arm's
length
investors.
While
Marion
Minshull
Enterprises
Ltd.
is
not
one
of
the
applicants
herein,
there
are
outstanding
tax
assessments
against
that
corporation
for
the
taxation
years
1980-1982,
that
are
in
excess
of
$300,000.
Moreover,
the
information
obtained
by
the
Minister
following
service
of
the
requests
for
information
reveal
that
on
April
25,
1984,
the
sum
of
$73,000
in
cash
was
withdrawn
by
Robert
Minshull
from
the
account
of
Marion
Minshull
Enterprises
Ltd.
with
the
Royal
Bank
of
Canada.
On
June
7,
1984,
the
sum
of
$39,000
was
transferred
from
Marion
Minshull
Enterprises
Ltd.
to
Lawrence
Minshull.
Bridge
City
Properties
Ltd.,
another
of
the
corporations
controlled
by
the
Minshull
family,
is
indebted
to
the
Minister
in
the
sum
of
$25,194.08
for
outstanding
taxes
assessed
in
1985,
and
covering
the
taxation
years
1981-1983.
Further
arbitrary
assessments
were
issued
against
the
company
in
1985
totalling
$22,972.79.
Early
in
the
year
1984,
Bridge
City
Properties
Ltd.
transferred
a
30-unit
apartment
to
R.
&
L.
Investments
Ltd.
for
a
stated
price
of
$502,577.
On
the
same
date,
Lawrence
Minshull
personally
transferred
$71,000
to
Bridge
City
Properties
Ltd.,
and
these
funds
were
apparently
used
by
R.
&
L.
Investments
Ltd.
to
complete
payment
of
the
purchase
price
of
the
apartment
building.
In
the
same
year
up
to
December
1984,
a
total
of
$27,932.11
was
transferred
from
Bridge
City
Properties
Ltd.
to
R.
&
L.
Maintenance,
an
unincorporated
business
owned
and
operated
by
Lawrence
Minshull.
While
the
inability
of
the
taxpayer
to
pay
the
amount
of
assessments
made
by
the
Minister
is
not
a
factor
that
should
be
considered
in
determining
the
question
of
jeopardy,
the
actions
of
the
taxpayer
may
reveal
circumstances
that
are
relevant
to
such
determination.
In
the
case
of
Robert
Minshull,
enforcement
proceedings
were
taken
with
respect
to
unpaid
income
taxes
in
the
amount
of
approximately
$10,000
assessed
in
the
year
1972.
Following
the
issuance
of
demands
on
third
parties
and
the
filing
of
writs
of
execution,
payment
arrangements
supported
by
guarantees
were
obtained
from
Marion
Minshull
Enterprises
Ltd.
and
Bridge
City
Enterprises
Ltd.
These
arrangements
were
not
kept,
and
full
recovery
was
not
obtained
until
August
1980
as
a
result
of
caveats
filed
against
real
property
owned
by
the
corporations.
In
1984
and
1985
arbitrary
assessments
were
issued
against
Marion
Minshull
Enterprises
Ltd.,
R.
&
L.
Investments
Ltd.,
and
Bridge
City
Properties
Ltd.
The
position
of
the
Minister
is
that
none
of
these
corporations
have
filed
corporate
returns
going
back
to
the
years
1979-1982.
Corporate
assets
have
been
placed
beyond
reach
of
the
Department
through
the
actions
of
Robert
Minshull,
An
example
of
such
action
is
to
be
found
in
the
affidavit
of
Robert
Minshull
filed
in
support
of
his
application
and
that
of
R.
&
L.
Investments
Ltd.,
where
he
deposes
that
the
sum
of
$41,900,
previously
noted
as
having
been
withdrawn
from
the
investment
account
of
R.
&
L.
Investments
Ltd.
with
Midland
Doherty
Limited,
was
done
pursuant
to
a
loan
agreement
between
R.
&
L.
Investments
Ltd.
and
Sunset
Bay
Resort
Inc.,
a
company
operating
a
resort
at
Emma
Lake,
Saskatchewan,
and
controlled
by
the
Minshull
family.
Robert
Minshull
also
provided
information
with
respect
to
the
purchase
of
the
Canadian
gold
sovereigns
by
Marion
Minshull
Enterprises
Ltd.
for
the
sum
of
$94,265
in
1983.
He
states
in
his
affidavit
that
the
investment
group
is
purchasing
such
coins
in
order
to
deface
them,
thereby
increasing
the
value
of
the
remaining
coins
held
by
the
investors.
He
says
further
that
the
sum
of
$22,719.33
was
moneys
that
R.
&
L.
Investments
Ltd.
had
available
to
purchase
another
gold
sovereign.
The
money
was
transferred
to
Robert
Minshull
personally,
as
the
auction
company
in
London,
England
preferred
personal
bids
as
opposed
to
corporate
bids,
and
he
personally
made
up
the
difference
when
he
found
that
the
purchase
price
of
the
coin
exceeded
the
amount
available
from
R.
&
L.
Investments
Ltd.
Lawrence
R.
Minshull
filed
an
affidavit
objecting
to
the
assessments,
and
attempted
to
explain
the
reasons
for
the
transfers
of
funds
between
himself
and
Bridge
City
Properties
Ltd.
He
says
that
the
sum
of
$71,000
transferred
to
the
company
in
1984
represented
part
of
the
purchase
price
of
the
30-unit
apartment
building.
It
was
drawn
out
of
the
Credit
Union
account
for
R.
&
L.
Maintenance,
an
unincorporated
company
owned
and
operated
by
Lawrence
R.
Minshull
and
the
payment
was
regarded
as
a
shareholder's
loan
from
Lawrence
R.
Minshull
to
R.
&
L.
Investments
Ltd.
It
is
not
known
whether
this
transaction
was
documented
and
recorded
by
company
minutes,
but
it
was
obviously
not
information
that
was
available
to
the
Minister.
With
respect
to
the
advances
totalling
$27,932.81,
paid
to
R.
&
L.
Maintenance
by
Bridge
City
Properties
Ltd.,
Lawrence
Minshull
says
that
of
this
amount,
$12,882.80
represented
janitorial
and
other
services
rendered
by
himself
to
the
company,
and
$13,140
was
for
services
performed
by
another
unincorporated
body,
operated
by
him
and
known
as
Bridge
City
Construction.
Lawrence
Minshull's
explanations
with
respect
to
these
payments
are
puzzling.
The
cheque
in
the
first
case
was
only
made
payable
to
R.
&
L.
Maintenance
because
of
the
fact
that
the
Royal
Bank
of
Canada
had
originally
refused
to
honour
a
cheque
issued
to
himself.
The
cheque
was
depos
ited
in
the
R.
&
L.
Maintenance
account
at
the
Credit
Union
so
that
Lawrence
Minshull
could
receive
the
funds
to
which
he
was
entitled.
The
second
cheque
for
$13,140
represented
renovations
for
which
a
cheque
from
an
insurance
company
was
received
and
was
payable
to
Bridge
City
Construction.
While
this
unincorporated
company
was
operated
by
Lawrence
Minshull
personally,
he
says
that
Robert
Minshull
deposited
the
proceeds
of
the
cheque
into
the
bank
account
of
Bridge
City
Properties
Ltd.
as
a
favour,
and
then
made
out
a
cheque
for
the
like
amount
in
favour
of
R.
&
L.
Maintenance,
which
was
deposited
into
its
account
at
the
Credit
Union.
The
only
other
matter
to
which
reference
should
be
made
is
the
explanation
given
by
Robert
Minshull
and
Lawrence
R.
Minshull
in
an
attempt
to
account
for
the
failure
to
file
income
tax
returns
on
behalf
of
the
family
corporations.
Lawrence
R.
Minshull
says
that
it
was
agreed
among
all
the
officers
and
shareholders
of
the
companies
that
Robert
Minshull
along
with
the
companies'
accountants
were
to
prepare
and
file
the
returns.
Robert
Minshull
deposes
that
a
significant
portion
of
the
business
records
for
these
companies
went
missing,
and
that
while
he
has
endeavored
to
rebuild
such
records,
he
has
been
unable
to
do
so
to
date
due
to
personal
circumstances.
I
have
difficulty
in
accepting
this
explanation,
particularly
when
the
failure
to
file
returns
goes
back
to
the
taxation
year
1979
in
one
case.
I
find
it
difficult
to
envisage
“personal
circumstances"
of
such
magnitude
as
would
justify
the
inability
to
prepare
and
file
returns
for
such
a
lengthy
period
of
time.
Assistance
from
court
decisions
as
to
the
meaning
and
effect
of
the
applicable
sections
of
the
Income
Tax
Act
is
limited
as
the
provisions
were
only
recently
enacted.
Counsel
have
provided
me
with
three
decisions,
all
by
the
Trial
Division
of
the
Federal
Court
of
Canada,
where
section
225.2
has
been
considered,
and
in
all
likelihood,
these
are
the
only
cases
to
date
in
which
reasons
for
judgment
have
been
delivered.
The
cases
are
Laframboise
v.
The
Queen,
[1986]
2
C.T.C.
274;
86
D.T.C.
6396;
Danielson
v.
Deputy
A-G
Canada
and
M.N.R.,
[1986]
2
C.T.C.
380;
86
D.T.C.
6518;
and
1853-9049
Quebec
Inc
v.
The
Queen,
[1986]
2
C.T.C.
486;
87
D.T.C.
5031,
decision
of
the
trial
division
of
the
Federal
Court
by
Rouleau,
J.
dated
November
18,
1986.
In
the
latter
case,
7853-9049
Quebec
Inc.,
Mr.
Justice
Rouleau
reviewed
the
history
of
the
legislation,
quoting
extracts
from
a
speech
to
the
House
of
Commons
by
the
parliamentary
secretary
to
the
Minister
of
Finance
reported
in
the
House
of
Commons
debates
on
September
24,
1985.
Therein,
the
purpose
of
the
amendments,
namely,
collection
restrictions,
payment
of
contested
taxes,
and
preventative
measures
against
abuses
of
the
new
system
were
reviewed
at
some
length.
Following
the
quoting
of
these
extracts
from
the
speech
of
the
parliamentary
secretary,
Rouleau,
J.
expressed
his
agreement
with
the
observation
of
Joyal
J.
in
Laframboise
to
the
effect
that
the
new
rules
represented
a
considerable
departure
from
a
long-standing
provision
in
the
Income
Tax
Act
and
were
meant
to
dampen
considerably
the
right
of
the
Minister
to
collect
a
tax
until
various
avenues
of
appeal
had
been
exhausted.
These
new
rules
require
that
the
judge
look
at
the
grounds
on
which
the
Minister
has
made
a
direction
and
decide
whether
the
exceptional
steps
taken
by
the
Minister
are
justified.
In
Danielson
v.
Deputy
A-G
Canada
and
M.N.R.,
McNair,
J.
at
page
381
(D.T.C.
6519)
sets
out
the
test
that
should
be
applied
in
making
such
determination
in
the
following
words:
In
my
judgment,
the
issue
goes
to
the
matter
of
collection
jeopardy
by
reason
of
the
delay
normally
attributable
to
the
appeal
process.
The
wording
of
subsection
225.1(1)
would
seem
to
indicate
that
it
is
necessary
to
show
that
because
of
the
passage
of
time
involved
in
an
appeal
the
taxpayer
would
become
less
able
to
pay
the
amount
assessed.
In
my
opinion,
the
fact
that
the
taxpayer
was
unable
to
pay
the
amount
assessed
at
the
time
of
the
direction
would
not,
by
itself,
be
conclusive
or
determinative.
Moreover,
the
mere
suspicion
or
concern
that
delay
may
jeopardize
collection
would
not
be
sufficient
per
se.
The
test
of
"whether
it
may
reasonably
be
considered"
is
susceptible
of
being
reasonably
translated
into
the
test
of
whether
the
evidence
on
balance
of
probability
is
sufficient
to
lead
to
the
conclusion
that
it
is
more
likely
than
not
that
collection
would
be
jeopardized
by
delay.
Applying
these
principles
to
the
facts
before
me,
I
have
no
hesitation
in
concluding
that
the
Minister
has
satisfied
the
burden
of
justifying
the
directions
that
were
made.
The
only
reasonable
conclusion
to
be
drawn
from
the
uncontradicted
evidence
of
transfers
of
substantial
sums
of
money
following
shortly
upon
service
of
requests
to
pay
and
notices
requiring
information
on
the
applicants
is
that
the
majority
of
such
transfers
were
carried
out
to
avoid
efforts
by
officers
of
the
tax
department
to
enforce
payment
of
outstanding
taxes.
The
fact
that
moneys
deposited
with
related
corporations
were
transferred
to
individual
family
members
for
the
purchase
of
gold
sovereigns
outside
Canada
suggest
that
steps
were
being
taken
to
place
assets
of
the
corporation
beyond
reach
of
the
Minister.
The
failure
to
file
tax
returns
on
behalf
of
the
corporations
for
a
number
of
years
and
the
unsatisfactory
explanation
for
such
failure
is
further
evidence
of
conduct
on
the
part
of
the
taxpayers
designed
to
interfere
with
and
obstruct
the
efforts
of
officers
of
the
department
to
review
the
activities
of
these
corporations
and
make
proper
assessments
with
respect
to
a
tax
liability.
If
the
financial
activities
of
these
individuals
and
their
related
corporations
are
permitted
to
continue
in
the
manner
they
have
in
the
past,
and
it
is
extremely
likely
this
will
occur,
the
ability
of
the
Minister
to
effect
collection
of
the
assessments
presently
outstanding
is
bound
to
be
seriously
jeopardized
in
the
same
manner
as
it
has
been
to
date.
The
evidence
satisfies
me
that
the
directions
of
the
Minister
were
justified
in
the
circumstances.
The
applications
to
review
such
directions
in
each
of
the
three
cases
are
without
merit
and
are
dismissed.
As
provided
by
subsection
225.2(8)
of
the
Act,
there
will
be
no
order
as
to
costs.
Applications
dismissed.
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