Rothstein J.:-This is a review, pursuant to subsection 231.2(5) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act"), of an order of Muldoon J., a judge of this Court. The sequence of events giving rise to this review are as follows:
Rothstein J.:-Th is is an application for an order suspending the operation of orders made pursuant to section 231.2 of the Income Tax Act requiring the respondents to provide information relating to unnamed persons. The motion states that the orders have been appealed to the Federal Court of Appeal and that it is just in the circumstances to suspend the orders pending appeal. Reliance is placed on Rule 341 A.
Rothstein J.:—This is an appeal by way of trial de novo from a decision dated February 26, 1992 of Judge Taylor of the Tax Court of Canada, in which he allowed the appeal of the taxpayer ("Lehmann") against assessments made
Joyal J.:-The plaintiff is appealing a decision of the Tax Court of Canada rendered on December 17, 1987, wherein it allowed the defendant’s appeal to the extent that the limitative provisions of subsection 31(1) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c. 63) (the "Act”) did not apply to the defendant for its 1982 taxation year. The case before this Court now proceeds by way of a trial de novo.
Rothstein J.:—
Rouleau J.:-This is an appeal from a decision of the Minister of National Revenue’s assessment wherein it was determined that payments received under a "wage loss replacement plan" were taxable as income.
Tremblay-Lamer J.:-This is a motion to certify a class for a class action suit. The action itself is based on the ruling of the Federal Court of Appeal in Thibaudeau v. Canada. [1994] 2 C.T.C. 4, 94 D.T.C. 6230 (since reversed by the Supreme Court: [1995] 1 C.T.C. 382, 95 D.T.C. 5273). In that decision, the Court of Appeal found that a provision of the Income Tax Act, R.S.C. 1985 (5th Supp.), c.
Marceau J.A.:-I have had the advantage of reading the reasons for judgment prepared by my brother McDonald. Unfortunately, my analysis of the legal principles applicable to the facts of this case does not lead me to the conclusion which he has
Simpson J.:-On December 16, 1982, Revenue Canada assessed the Canadian Imperial Bank of Commerce (the ”CIBC”) in the amount of $243,440.69 pursuant to section 153 of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72, c.
MacGuigan J.A.:-This case, dealing with an income tax assessment for 1980, began before the Tax Court, where the appellant disputed the Minister of National Revenue’s determination for capital gains purposes of the fair market value of $100 an acre as at
