Prince Albert Pulp Company Limited v. Her Majesty the Queen, [1990] 2 CTC 339, 90 DTC 6527 -- text
Strayer, J.: —
Strayer, J.: —
Martin, J.:—At issue in this matter is whether $300,000 paid by Outboard Marine Corporation of Canada Ltd. (“OMC”) upon the termination of its distributorship agreements with the plaintiff should be characterized as an income payment, as the defendant claims,
McNair, J.: —This action is an appeal by the plaintiffs as personal representatives of the deceased taxpayer, Evan Wesley George Bodrug, from an income tax reassessment for the 1980 taxation year, whereby the Minister of National Revenue determined that
Oliver, J.:—Kalvan Gill was charged with 13 counts under the Income Tax Act, R.S.C. 1952, c. 148 (as amended), the "Act". Count 1 reads as follows:
Count 1
Teitelbaum, J.:—The above case was heard on June 13 and continued on August 15, 1990 in Halifax, Nova Scotia. In that both cases are similar in nature and are based on similar facts,a request was made that they be heard together and that
Muldoon, J.:—The plaintiff, by an ill-drafted amended statement of claim, filed October 31, 1988, in effect, alleges that the Department of National Revenue garnished from the debtors of a corporation, Perrin Turner Ltd., moneys which were owing to him. This,
Per Curiam: —Both respondents were charged with tax evasion contrary to paragraph 239(1)(d) of the Income Tax Act. The respondent Holmes was also charged with making a false or deceptive statement in his income tax return
Pinard, J.: —Upon reading all the affidavits and the other documents filed, upon hearing the testimony given by Raj Vohora, upon considering the particular situation and the nature of this particular case, and upon serious consideration of the arguments
Wright, J.: —
The Issue:
Does the Royal Bank of Canada ("Bank") have a prior right to moneys held by Saskatchewan Power Corporation which are also claimed by Revenue Canada, Taxation?
Montgomery, J. [Orally]: —