Rouleau, J.:—A preliminary matter was raised by counsel for the plaintiff, regarding burden of proof and the order in which evidence is to be adduced at trial. I ruled that the Minister of National Revenue’s (the Minister) burden of proof with
Archambault J. (orally):— I think the issue of whether or not to order particulars really becomes a balancing act in the final analysis. On the one hand, in accordance with section 587, the Court may, if it is satisfied that it is necessary
Halvorson J.:— This was a hearing to determine the priority among claimants to insurance money paid into Court by the defendant, The Prudential Assurance Co.
Execution creditors contend the money should be shared pro rata pursuant to the Creditors' Relief Act, R.S.S. 1978, c. C-46. Garnishors assert prior rights under the Attachment of Debts Act, R.S.S. 1978, c. A-32. If the latter Act governs, there is an issue concerning the date upon which the insurance money became due and therefore attachable.
MacPherson J.:—
Orsborn J.:—The Court holds $19,301.01, representing holdback funds paid in by the Town of Bonavista, as owner, to vacate various mechanics’ liens filed against the town arising out of its contract with Atlantic Technologists Ltd. (Atlantic). There are three claimants:
Kempo J.T.C.C.:—The appellant appeals from a notice of reassessment bearing number 7049 dated January 16, 1991. The basis for the reassessment concerned his liability as a director of Fortune West Enterprises Inc. (the "company") for their failure to remit source
Christie A.C.J.T.C.C.:-When these status hearings under section 125 of the Tax Court of Canada Rules (General Procedure) were called for hearing the appellant took the position that he having made an assignment in bankruptcy these appeals were stayed by operation
Kempo J.T.C.C.:-These informal procedure appeals concern Mr. Korpan’s 1991 and 1992 taxation years.
Teskey J.T.C.C.:—The appellant appeals from an assessment of income tax for the year 1985, wherein the Minister of National Revenue (the "Minister") added to the appellant’s income an additional amount of $145,212 pursuant to paragraph 6(l)(a) of the Income
P.R. Dussault J.T.C.C.:-These are appeals from assessments made for the appellant’s 1987, 1988 and 1989 taxation years, according to which the Minister of National Revenue (the "Minister") determined that transactions in 1987 and 1988 concerning a lot situated in
