Harper J.

Part One: Statement of Facts

The instant matter is a Summary Conviction prosecution which was commenced on the Information of one Claudette Miller and is dated the second day of December, 1991. The Jurat

Rowles J.

Background

American Express Bank Ltd. (’’the bank") is the holder of debentures and general security agreements which cover three hotels and their contents. 1873 Holdings Ltd. ("1873 Ltd.") is the registered owner of the hotel

Agrios J.— The company borrowed money from the bank and gave the bank many forms of security for it, both under the Bank Act and under provincial law. Some years later, the company made income tax deductions from its payroll,

Rouleau, J.:—This is an appeal from a decision of the Tax Court of Canada dismissing the plaintiffs appeals from reassessments made by the Minister of National Revenue with respect to the 1977, 1978, 1979 and 1980 taxation years.

Rouleau J.:—This is an appeal by the Crown from a decision of the Tax Court of Canada dated January 8, 1990.

Rothstein J.:—This is a case involving the attribution rules of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act"). The attribution rules are intended to protect the integrity of the progressive tax rate system as it

Noel J .:-Each of the appeals set out in the style of cause raises the same point, and they were heard jointly on common evidence. The issue is the legal effect, from an income tax perspective, of two certificates issued by the Central

Major J. (Sopinka, L-Heureux-Dubé, J J, concurring):—

Jerome, A.C.J.:—The plaintiff’s claim to file an amended statement of claim pursuant to Rule 420 of the Federal Court Rules came on for hearing before me at Toronto, Ontario, on March 5, 1995. The action appeals the Minister’s reassessment of the plaintiff’s