Smith v. Her Majesty the Queen, [1996] 3 CTC 2697, [1996] DTC 1638 -- text
McArthur J.T.C.C.: — John Smith entered into an agreement in May 1989 to provide services to St. Joseph’s General Hospital. In December of that year, he assigned the contract to 442849 Ontario Limited. The hospital paid the company $32,100 in