Décary J.A. (Hugesson and Robertson, J J. A., concurring): — This application for judicial review of a decision of the Tax Court of Canada raises the question, once again, of the applicability and effect of subsection
Gonthier J.T.C.C.: —
La Forest J. (orally): It will not be necessary to hear from you Ms. Burns. The Court is ready to give judgment and I will ask Mr. Justice lacobucci to deliver the judgment of the Court.
Cullen J.: This is an action by the plaintiff taxpayer, Liampat Holdings Ltd. (“the plaintiff’ or “the taxpayer”), arising out of reassessments by the defendant Minister of National Revenue (“the defendant” or “the Minister”) for the 1981 and 1982 taxation
Hargrave P. — I initially dealt with this motion in writing pursuant to Rule 324, to strike out the action for want of prosecution, by granting that relief to the defendant on June 23, 1995, the plaintiff filing no material. Subsequently,
Denault J.: — In the Court’s opinion, there is a serious question to be tried in the appeal filed against the orders of July 25 and 28, 1995. It appears that the judge simply quashed the demands for payment sent by the Department of National Revenue even though the motion before the judge, which was made by Bâtiment Fafard International Inc., asked only for an interim order to inform those concerned that they were not required to pay.
La Forest J.: - This appeal involves the issue whether compensation received by an “employee” from his “employer” pursuant to a settlement regarding liability for the employer’s unilateral decision to cancel a contract of employment before the employee
Iacobucci J.:-This appeal involves the question of whether interest can be deducted by a taxpayer on a loan to purchase shares when the shares have been disposed of in a rollover transaction.
Heald D.J.: — The Plaintiff herein filed a Statement of Claim in which he appealed Notice of Reassessment No. 1911903, dated July 13, 1989 (the “Second Reassessment”) in respect of his 1981 taxation year. This Second Reassessment had been confirmed
Rouleau J.: — This is an appeal from the decision of the Tax Court of Canada dated June 18, 1991, wherein it was held that subparagraph 40(2)(g)(ii) of the Income Tax Act, R.S.C. 1952, c. 148 (am. S.C. 1970-71-72,
