The Royal Bank of Canada v. The Queen, 84 DTC 6439, [1984] CTC 573 (FCTD), aff'd 86 DTC 6390, [1986] 2 CTC 211 (FCA) -- text
Muldoon, J:—The parties here have agreed to submit a special case in lieu of trial and have presented an agreed statement of facts followed by a question of law. Their agreed statement of facts runs as follows: