Hudson Bay Mining and Smelting Co. v. R., [1997] 2 CTC 2419, 96 DTC 1246 -- text
Bell T.C.J.:
Bell T.C.J.:
Garon T.C.J.:
These are appeals from income tax assessments dated May 2, 1990 and August 3, 1990 for the 1989 taxation year.
Lamarre Proulx T.C.J.:
The appellant is appealing the assessments by the Minister of National Revenue (the “Minister”) for the 1988 and 1989 taxation years.
Lamarre Proulx T.C.J.:
This concerns a motion for disclosure of a legal opinion obtained by officers of the Minister of National Revenue (“the Minister”) on an assessment under appeal.
Rip T.C.J.:
Christie A.C.J.T.C.:
On December 9, 1996 the parties were informed that this application would be dismissed and that reasons for that decision would follow.
Bowman T.C.J. (Orally):
Bell T.C.J.:
Rip T.C.J.:
Beaubier T.C.J.:
These matters were heard jointly on common evidence pursuant to the Informal Procedure at Saskatoon, Saskatchewan, with the consent of the parties. The Appellants’ father, Murray McMillan, was the only witness.