Seaway-Levy Technical & Financial Limited v. Minister of National Revenue, [1991] 1 CTC 2260, 91 DTC 323 -- text
Sarchuk, T.C.J.:—The appeals of Seaway-Levy Technical & Financial Ltd. (Seaway) are from reassessments of tax with respect to its 1981, 1982 and 1983 taxation years. The issue before me arises in the following manner.