In the Matter of the Bankruptcy of Country Inns Inc., [1995] 1 CTC 75, 94 DTC 6650 -- text

Cote J. (Hetherington and Irving, JJ.A., concurring):—

A. The issue

A panel of this Court heard three appeals together. In each, one party is The Queen, as represented by the Minister of National Revenue (here called the Minister). And in each case the other party is a bank or the Alberta Treasury branches. Each appeal is a priority contest between the Minister’s garnishee summons, and a general assignment of book debts to the bank or Treasury branch.

Edwin J. Byram v. Her Majesty the Queen, [1995] 1 CTC 66, [1995] DTC 5069 -- text

Wetston J.:—This is an appeal from a reassessment of income by the Minister of National Revenue, dated June 28, 1988, in respect of the plaintiff’s 1982, 1983, 1984, 1985 and 1986 taxation years. Each court file corresponds to one taxation year; the

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